Browse Advisory Opinions

Concerning a health system's provision of professional consultative services to low-income schoolchildren in predominantly rural areas through a sponsored telemedicine network.

Concerning a municipal corporation that is proposing to reduce its fees for ambulance services for residents by an amount consistent with their cost-sharing obligations.

Concerning participation as a volunteer pathology laboratory for a charitable foundation's medical assistance program for low-income, uninsured patients.

Concerning a proposed program to provide free vision screening tests for infants.

Concerning a marketing company's arrangement to design, develop, and implement physician surveys conducted on behalf of pharmaceutical firms.

Concerning a proposal by a political subdivision of a municipality that owns and operates an ambulance service to treat revenue received from a special utility assessment as payment of otherwise applicable cost-sharing amounts due from residents.

Concerning the waiver of Part B cost-sharing obligations for equipment and supplies used by Medicare beneficiaries to monitor blood glucose levels in a clinical trial sponsored by the National Institutes of Health.

Concerning a proposal to reintegrate a medical group and a hospital that were originally a single entity and whether the proposed arrangement would violate the anti-kickback statute.

Concerning an arrangement between a hospital and an ambulance company providing emergency air ambulance services to trauma victims in a rural setting, and whether the provision of free helipad and crew resting quarters would violate the anti-kickback statute.

Concerning whether a joint venture ownership of a freestanding magnetic resonance imaging center in a rural area could potentially violate the anti-kickback statute.

Concerning a proposed joint venture between a medical center and a radiology group to own and operate an outpatient open magnetic resonance imaging facility.

Concerning an ambulance company's proposed arrangement to collect a fixed annual subscription fee in lieu of Medicare Part B cost-sharing amounts from its members.

Concerning a proposed arrangement by which a Medigap plan would indirectly contract with hospitals for discounts on the otherwise applicable Medicare inpatient deductibles for its policyholders and would also, at the time of the next policy renewal, reduce the premium for policyholders utilizing a network hospital for an inpatient stay.

Concerning a proposed arrangement by which a municipal corporation that owns and operates an ambulance service would treat revenue received from local real estate taxes as payment as applicable copayments/deductibles due from residents.

Concerning a proposed arrangement that would involve a company developing and managing distinct part inpatient rehabilitation units located within general acute care hospitals in exchange for a management fee calculated on a per patient per day basis.

Concerning an arrangement involving a medical center providing physician services to a county-owned women's health clinic for an annual below fair-market value fee, along with inpatient hospital services for the county clinic's primarily indigent and low-income, self-paying patients at no charge.

Concerning a proposed arrangement under which a renal dialysis facility would provide acute hemodialysis services to a hospital district's inpatients, provide outpatient chronic hemodialysis services to some of the hospital district's indigent patients, and purchase certain hemodialysis equipment from the hospital district.

Concerning a proposed ambulatory surgical center (ASC) arrangement that would be jointly owned by a hospital and a multi-specialty group practice with a substantial number of physician members who would not personally use the ASC.

Concerning a proposed modification to a drug company's patient assistance program to pay Medicare Part B cost-sharing amounts for financially needy beneficiaries following surgery.

Concerning a proposed program by a provider of home health care services to provide free medical-alert pagers and pager monitoring service to homebound patients during the period such patients are receiving the company's home health services.