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 indirectly contract with hospitals for discounts on the otherwise applicable Medicare inpatient deductibles for its policyholders and, in turn, would provide a premium credit of $100 to policyholders who use a network hospital for an inpatient stay.

Regarding a retail pharmacy chain's proposal to allow Federal health care program beneficiaries to participate in a paid membership program that includes discounts on certain prescriptions and clinic services.

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

Regarding a pharmaceutical manufacturer's proposal to replace products that require specialized handling that could not be administered to patients for certain reasons, at no additional charge to the purchaser.

Regarding a hospital outpatient facility's proposal to reduce or waive, on a non-routine, unadvertised basis, cost-sharing amounts owed by financially needy Medicare beneficiaries for items and services furnished in connection with a clinical research study.

Regarding a proposed arrangement in which grants would be provided by a non-profit, charitable organization to financially needy Medicare beneficiaries in order to subsidize their costs of medical care.

Regarding a hospital system's proposal to provide free or reduced-cost lodging and meals to certain financially needy patients.

Regarding: (i) a proposal to waive cost-sharing obligations incurred by individuals for health care services required for participation in a government-funded clinical research study (the "Proposed Arrangement"); and (ii) the payment of a stipend to study participants for the time and effort required to participate in study visits.

Regarding a laboratory's proposal to provide services consisting of the labeling of test tubes and specimen collection containers at no cost to dialysis facilities.

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

Regarding a local health care district's proposal to cooperate with another district to jointly fund the cost of a transportation coordinator to educate patients about local transportation options and subsidize certain forms of transportation for patients with financial need.

Regarding a proposal to install a computerized point-of-care vaccine storage and dispensing system in physicians' offices for the physicians' use.

Regarding an arrangement in which a hospice would make a supplemental payment to the nursing facilities in which the hospice's dually eligible patients reside when the nursing facilities-instead of the hospice-receive payment for their patients' room and board expenses.

Concerning a nonprofit, tax-exempt, charitable organization's proposal to provide financially-needy patients with grants to defray their cost-sharing obligations for drugs and/or devices to treat brain tumors and conditions incident to brain tumors.

Regarding a savings card program under which individuals who have prescription drug coverage under Medicare Part D receive discounts on a drug that is statutorily excluded from coverage.

Regarding a proposal by a nonprofit, tax-exempt, charitable organization to provide assistance with cost-sharing obligations to financially needy individuals, including Medicare and Medicaid beneficiaries, diagnosed with Multiple Sclerosis, cancer, or rheumatoid arthritis.

Regarding your proposal for an entity to purchase the remaining five percent ownership interest in a group purchasing organization.

Regarding the use of a “preferred hospital” network as part of Medicare Supplemental Health Insurance (“Medigap”) policies, whereby [name redacted] would indirectly contract with hospitals for discounts on the otherwise-applicable Medicare inpatient deductibles for its policyholders and, in turn, would provide a premium credit of $100 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 three insurance companies would indirectly contract with hospitals for discounts on the otherwise-applicable Medicare inpatient deductibles for their policyholders and, in turn, would provide a premium credit of $100 to policyholders who use a network hospital for an inpatient stay.

Regarding a proposal by a nonprofit, tax-exempt, charitable organization to subsidize Medicare Part D premium and cost-sharing obligations owed by financially needy patients with end-stage renal disease and chronic kidney disease.