Browse Advisory Opinions

Regarding the use of a "preferred hospital" network as part of Medicare Supplemental Health Insurance ("Medigap") policies, whereby an insurance company would contract with a preferred hospital organization to provide discounts on the otherwise-applicable Medicare inpatient deductibles for its policyholders and, in turn, would provide a premium credit of $100 off the next renewal premium to policyholders who use a network hospital for an inpatient stay.

Regarding financial assistance for transportation, lodging, and meals provided by a pharmaceutical manufacturer to certain patients potentially eligible for treatment with the pharmaceutical manufacturer’s drug.

Regarding the use of a "preferred hospital" network as part of Medicare Supplemental Health Insurance ("Medigap") policies, whereby an insurance company would contract with a preferred hospital organization to provide discounts on the otherwise-applicable Medicare inpatient deductibles for its policyholders and, in turn, would provide a premium credit of $100 off the next renewal premium to policyholders who use a network hospital for an inpatient stay.

Regarding a spinal implant manufacturer’s proposal to offer its products to hospitals at a reduced price if the hospitals agree to assume certain duties related to the products.

Regarding the use of a "preferred hospital" network as part of Medicare Supplemental Health Insurance ("Medigap") policies, whereby an insurance company would contract with a preferred hospital organization to provide discounts on the otherwise-applicable Medicare inpatient deductibles for its policyholders and, in turn, would provide a premium credit of $100 off the next renewal premium to policyholders who use a network hospital for an inpatient stay.

Regarding the use of a "preferred hospital" network as part of Medicare Supplemental Health Insurance ("Medigap") policies, whereby an insurance company would contract with a preferred hospital organization to provide discounts on the otherwise-applicable Medicare inpatient deductibles for its policyholders and, in turn, would provide a premium credit of $100 off the next renewal premium to policyholders who use a network hospital for an inpatient stay.

Regarding the use of a "preferred hospital" network as part of Medicare Supplemental Health Insurance ("Medigap") policies, whereby an insurance company would contract with a preferred hospital organization to provide discounts on the otherwise-applicable Medicare inpatient deductibles for its policyholders and, in turn, would provide a premium credit of $100 off the next renewal premium to policyholders who use a network hospital for an inpatient stay.

Regarding an investment by a health system, certain surgeons, and a management company in an ambulatory surgery center.

Regarding a free drug provided by a pharmaceutical manufacturer to certain patients to whom the manufacturer's drug has been prescribed.

Regarding a program where a pharmaceutical manufacturer provides financial assistance for travel, lodging, and other expenses to certain patients prescribed the manufacturer's drug.

Regarding a federally qualified health center's proposal to offer gift cards to incentivize certain pediatric patients to attend rescheduled preventive and early intervention care appointments.

Regarding a web-based platform where health care facilities and clinicians would, in particular circumstances, remit to patients and the patients' payors a portion of the claims for certain services for which payment may be made by the Medicare program as a secondary payor.

Regarding a management company's provision of below fair market value Medicaid enrollment application assistance services to certain individuals and affiliated skilled nursing facilities' payments for those services in particular circumstances.

Regarding a pharmaceutical manufacturer's proposal to provide cost-sharing assistance directly to Medicare beneficiaries who are prescribed either of two formulations of its drug.

Regarding an arrangement under which a discount medical plan organization ("DMPO") pays chiropractors and chiropractic clinics a fee for each new DMPO member referred by the chiropractor or chiropractic clinic.

Regarding a hospital's provision of discounted training to a specified fire department's personnel at the hospital's facility.

Regarding a supermarket's proposal to expand its current loyalty program to allow customers to earn rewards points on out-of-pocket costs paid in connection with pharmacy purchases.

Regarding a proposed purchase of real estate from a limited liability company owned, in part, by an excluded individual.

Regarding a technology company's proposal to make visible to Federal health care program beneficiaries: (i) its online healthcare directory for searching and booking medical appointments, where healthcare professionals pay, or would pay, per-click or per-booking fees to be listed in the directory; and (ii) sponsored advertisements on its online healthcare directory and third-party websites, where healthcare professionals pay, or would pay, per-impression or per-click fees for such sponsored advertisements (the "Proposed Arrangement").

Regarding a program offered by a medical center that provides free, in-home follow-up care to eligible individuals with congestive heart failure (the "Current Arrangement") and the proposed expansion of this program to include certain individuals with chronic obstructive pulmonary disease.