Browse Advisory Opinions

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.

Regarding the use of a "preferred hospital" network as part of Medicare Supplemental Health Insurance ("Medigap") policies.

regarding a state academic medical center that in certain circumstances offers pregnant women: (1) transportation aid to and from the campus hospital for delivery; and (2) short-term lodging near the campus hospital.

Regarding the use of a "preferred hospital" network as part of Medicare Supplemental Health Insurance ("Medigap") policies, whereby [names redacted] (the "Requestors") 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 provide financial assistance to cover cost-sharing obligations associated with outpatient drug treatment owed by financially needy Medicare or Medicaid patients with a certain disease state.

Concerning a patient assistance program that assists underinsured patients with their prescription drug co-payment obligations.

Concerning grants provided by a nonprofit, charitable organization to financially-needy patients suffering from specific chronic or life-threatening diseases to defray the costs of prescription drug therapies.

Regarding a nonprofit, tax-exempt, charitable organization's proposal to provide assistance with out-of-pocket expenses for outpatient prescription drugs to financially needy insured patients, including, but not limited to, Medicare and Medicaid beneficiaries.

Regarding a non-profit, tax-exempt, charitable organization's proposal to provide financial assistance with copayment obligations, health insurance premiums, and insurance deductibles to patients, including Medicare and Medicaid beneficiaries, receiving treatment for [disease state redacted].

Regarding an arrangement by a nonprofit, tax-exempt, charitable organization to subsidize cost-sharing and premium obligations owed by financially needy Medicare or Medicaid patients with certain chronic diseases.

Regarding a proposal by a tax-exempt charitable organization to provide financial assistance with cost-sharing obligations for certain genetic tests to financially needy individuals, including but not limited to Medicare and Medicaid beneficiaries, and an existing practice of providing vouchers for free genetic tests to individuals who are uninsured or whose insurance does not cover genetic tests.

Regarding a proposal for a hospital to bill a radiology group for transcription of the radiology group's reports for individuals who are not hospital patients, but rather patients of a third-party clinic that provides the technical component of the radiology exams.

Regarding a proposal by a nonprofit, tax-exempt, charitable organization to provide financially needy persons who have certain diseases with grants to defray the costs of premiums and cost-sharing obligations under Medicare Part B, Medicare Part D, Medicare Supplementary Health Insurance, and Medicare Advantage.

Regarding a proposal by a nonprofit, tax-exempt, charitable organization to establish a foundation to provide financially needy cancer patients with grants to defray their out-of-pocket treatment costs.

Regarding an arrangement in which a nonprofit, tax-exempt, charitable organization provides certain therapy management services and assistance with Medicare cost-sharing obligations to financially needy Medicare beneficiaries undergoing medical treatment for certain diseases.