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HHS Office of Inspector General

Fraud Prevention & Detection / Advisory Opinions

Advisory Opinions

Advisory Opinions

2008

09/04/08


08/26/08

  • Advisory Opinion 08-10 (PDF) (concerning a proposal for a physician practice group to provide space, equipment and personnel to other physician practice groups through block leases)

08/07/08

  • Advisory Opinion 08-09 (PDF) (concerning an arrangement under which a medical center has agreed to share with groups of orthopedic surgeons and a group of neurosurgeons a percentage of the medical center’s cost savings arising from the surgeons’ implementation of a number of cost reduction measures in spine fusion surgical procedures)

07/25/08

  • Advisory Opinion 08-08 (PDF) (concerning an investment in an ambulatory surgery center by a group of surgeons and a health care corporation that owns hospitals)

07/07/08

  • Advisory Opinion 08-07 (PDF) (concerning a proposal for a health care system to provide $10 gift cards to patients whose service expectations were not met)

05/09/08

  • Advisory Opinion 08-06 (PDF) (concerning a laboratory's proposal to provide services consisting of the labeling of test tubes and specimen collection containers at no cost to dialysis facilities)

02/22/08

  • Advisory Opinion 08-05 (PDF) (concerning a pharmaceutical company's proposal to place in certain physicians' offices electronic kiosks that offer patients free disease state screening questionnaires)

02/12/08

  • Advisory Opinion 08-04 (PDF) (concerning a proposal to offer a free trial prescription program to hemophilia A patients who are Federal health care program beneficiaries)

02/08/08

  • Advisory Opinion 08-03 (PDF) (concerning a proposed arrangement by which a health care system would provide prompt pay discounts to Federal health care program beneficiaries and other insured patients in connection with both inpatient and outpatient care)

02/05/08

  • Advisory Opinion 08-02 (PDF) (concerning a marketing and research company's proposal to encourage physicians and other health care professionals to complete online surveys by offering them the opportunity to designate a public charity to which the company or one of its clients would make a monetary charitable contribution)

02/01/08

  • Advisory Opinion 08-01 (PDF) (concerning a non-profit corporation's program that arranges for pharmaceutical manufacturer patient assistance programs to provide donated drugs to free clinics and Federally qualified health centers (FQHCs) for use by financially-needy patients who do not have any form of outpatient prescription drug insurance coverage)

2007

01/14/08

  • Advisory Opinion 07-22 (PDF) (concerning an arrangement in which a hospital has agreed to share with a group of anesthesiologists a percentage of the hospital's cost savings arising from the anesthesiologists' implementation of a number of cost reduction measures related to anesthesia services provided during cardiac surgical procedures)

01/14/08

  • Advisory Opinion 07-21 (PDF) (concerning an arrangement in which a hospital has agreed to share with a group of cardiac surgeons a percentage of the hospital's cost savings arising from the surgeons' implementation of a number of cost reduction measures in certain surgical procedures)

01/03/08

  • Advisory Opinion 07-20 (PDF) (concerning an investment by a physician in an imaging center in a medically underserved area devastated by Hurricane Katrina)

01/03/08

  • Advisory Opinion 07-19 (PDF) (concerning an arrangement whereby a radiology group practice prepares written reports of its interpretations of radiology tests for a critical access hospital without charge to the hospital)

01/03/08

  • Advisory Opinion 07-18 (PDF) (concerning the management by a health care industry consultancy of a charitable organization's arrangements to subsidize patient cost-sharing and premium obligations)

12/26/07

  • Advisory Opinion 07-17 (PDF) (concerning a proposal by an excluded individual to license an invention to a new company)

12/13/07

  • Advisory Opinion 07-16 (PDF) (concerning a home health agency's practice of providing prospective orthopedic patients with free educational videos containing instructions for postoperative home-based convalescence)

12/10/07

  • Advisory Opinion 07-15 (PDF) (concerning the use of a "preferred hospital" network as part of a Medicare Supplemental Health Insurance ("Medigap") policy)

10/19/07

  • Advisory Opinion 07-14 (PDF) (concerning a county's exclusive contracts for emergency ambulance services, which set out how private ambulance companies should absorb the costs of transporting uninsured arrestees and reimburse the county for the costs of providing certain administrative and emergency dispatch services)

10/19/07

  • Advisory Opinion 07-13 (PDF) (concerning the addition of optometrists as owners of three single-specialty ophthalmology ambulatory surgical centers)


10/17/07

  • Advisory Opinion 07-12 (PDF) (concerning two proposals to accept low or no-cost bids for the provision of therapy services at state-operated veterans' homes)

10/03/07

  • Advisory Opinion 07-11 (PDF) (concerning a nonprofit, tax-exempt, charitable organization's proposal to establish a foundation to provide financially needy cancer patients with grants to defray their out-of-pocket treatment costs)

09/27/07

  • Advisory Opinion 07-10 (PDF) (concerning the physicians' on-call coverage and uncompensated inpatient care arrangement employed by a medical center)

08/28/07

  • Advisory Opinion 07-09 (PDF) (concerning a reward program under which certain consumers receive an annual reward based on the amount spent on purchases, including purchases of items covered by Federal health care programs)

07/30/07

  • Advisory Opinion 07-08 (PDF) (concerning a durable medical equipment supplier’s proposed arrangement to provide patients with a free in-home congestive heart failure assessment)

07/30/07

  • Advisory Opinion 07-07 (PDF) (concerning a cash donation to a senior residence program from a charitable foundation which shares ties with the program and with a local health system)

07/30/07

  • Advisory Opinion 07-06 (PDF) (concerning the management by a health care industry consultancy of a charitable organization’s arrangement to subsidize patient cost-sharing and premium obligations)

06/19/07

  • Advisory Opinion 07-05 (PDF) (concerning a proposal for certain physician investors in an established ambulatory surgery center to sell a portion of their ownership interests to a local hospital)

04/06/07

  • Advisory Opinion 07-04 (PDF) (concerning a pharmaceutical company’s patient assistance programs, which will provide free outpatient prescription drugs to financially-needy Medicare Part D enrollees entirely outside of the Part D benefit)

04/03/07

  • Advisory Opinion 07-03 (PDF) (concerning the use of rewards from credit card issuers for the benefit of a residential health care facility and its employees)

03/07/07

  • Advisory Opinion 07-02 (PDF) (concerning a hospital’s proposal to subsidize the cost of ambulance transportation for patients transported to the hospital from outside the hospital’s local area)

01/25/07

  • Advisory Opinion 07-01 (PDF) (concerning a hospital’s proposal to provide free dialysis services to chronic dialysis patients unable to obtain dialysis in their community)
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