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Advisory Opinions 2003 Archive

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2003

12-18-2003

Advisory Opinion 03-15 (PDF)
(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)

07-03-2003

Advisory Opinion 03-14 (PDF)
(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)

06-23-2003

Advisory Opinion 03-13 (PDF)
(concerning whether a joint venture ownership of a freestanding magnetic resonance imaging center in a rural area could potentially violate the anti-kickback statute)

05-29-2003

Advisory Opinion 03-12 (PDF)
(concerning a proposed joint venture between a medical center and a radiology group to own and operate an outpatient open magnetic resonance imaging facility)

05-28-2003

Advisory Opinion 03-11 (PDF)
(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)

05-15-2003

Advisory Opinion 03-10 (PDF)
(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)

04-25-2003

Advisory Opinion 03-9 (PDF)
(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)

04-10-2003

Advisory Opinion 03-8 (PDF)
(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)

03-26-2003

Advisory Opinion 03-7 (PDF)
(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)

Advisory Opinion 03-6 (PDF)
(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)

02-13-2003

Advisory Opinion 03-5 (PDF)
(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.)

02-12-2003

Advisory Opinion 03-4 (PDF)
(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)

Advisory Opinion 03-3 (PDF)
(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)

01-21-2003

Advisory Opinion 03-2 (PDF)
(concerning a medical center's proposed acquisition of an ownership interest in an established single-specialty [orthopedic] ambulatory surgery center, together with the execution of a series of related ancillary contracts.)

Advisory Opinion 03-1 (PDF)
(concerning the potential for the imposition of sanctions against a company which has made a good faith offer of employment to an excluded individual.)

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