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Advisory Opinions 2006 Archive

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2006

11-16-2006
Advisory Opinion 06-22 (PDF)
(concerning a proposed arrangement in which a hospital will 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)
11-09-2006
Advisory Opinion 06-21 (PDF)
(concerning a pharmaceutical company’s proposal to establish a patient assistance program to provide outpatient prescription drugs to financially-needy Medicare Part D enrollees entirely outside of the Part D benefit)
11-08-2006
Advisory Opinion 06-20 (PDF)
(concerning a durable medical equipment supplier’s practice of providing patients with free home oxygen until the patients qualify for Medicare coverage of oxygen, as well as the supplier’s proposed arrangement to provide patients with a free overnight oximetry test)
11-02-2006
Advisory Opinion 06-19 (PDF)
(concerning a pharmaceutical company’s proposal to establish a patient assistance program to provide outpatient prescription drugs to financially-needy Medicare Part D enrollees entirely outside of the Part D benefit)
Advisory Opinion 06-18 (PDF)
(concerning a volunteer services program for the provision of specialty medical care and professional development in rural areas, through which volunteers’ travel costs would be covered)
10-13-2006
Advisory Opinion 06-17 (PDF)
(concerning payment of certain compensation owed by the organizer of a dental preferred provider organization to a dental network marketing and management company in connection with the use of the dental network by a Federal employee health benefits plan)
10-10-2006
Advisory Opinion 06-16 (PDF)
(concerning a proposed arrangement for a durable medical equipment (“DME”) manufacturer to provide advertising assistance and reimbursement consulting services to some of its customers)
10-06-2006
Advisory Opinion 06-15 (PDF)
(concerning an arrangement under which a managed care company will disburse pay-for-performance financial incentives on behalf of a State's Medicaid program)
09-26-2006
Advisory Opinion 06-14 (PDF)
(concerning a pharmaceutical manufacturer’s proposal to establish a patient assistance program to provide the company’s drugs to financially-needy Medicare Part D enrollees outside of the Part D benefit)
09-25-2006
Advisory Opinion 06-13 (PDF)
(concerning a nonprofit, tax-exempt, charitable organization’s proposal to provide financially needy persons who have [diseases redacted] 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)
Advisory Opinion 06-12 (PDF)
(concerning a municipality’s exclusive contract arrangement for non-emergency inter-facility ambulance transport services)
Advisory Opinion 06-11 (PDF)
(concerning a municipality’s exclusive contract arrangement for non-emergency inter-facility ambulance transport services)
09-19-2006
Advisory Opinion 06-10 (PDF)
(concerning a nonprofit, tax-exempt, charitable organization’s practice of providing certain therapy management services and assistance with Medicare cost-sharing obligations to financially needy Medicare beneficiaries undergoing medical treatment for certain diseases)
08-25-2006
Advisory Opinion 06-09 (PDF)
(concerning a nonprofit, tax-exempt, charitable organization’s proposals to subsidize Medicare Part D premium and cost-sharing obligations owed by financially needy patients with end-stage renal disease and chronic kidney disease)
06-30-2006
Advisory Opinion 06-08 (PDF)
(concerning a free clinic's practice of dispensing drugs on behalf of patient assistance programs ("PAPs") sponsored by pharmaceutical manufacturers that provide free drugs to financially-needy patients, including some patients enrolled in the Medicare Part D outpatient prescription drug benefit)
06-29-2006
Advisory Opinion 06-07 (PDF)
(concerning a proposal by a municipality, which provides emergency medical services through a municipally owned and operated ambulance service, to treat revenue received from local taxes as payment of otherwise applicable cost-sharing amounts due from municipal residents)
05-08-2006
Advisory Opinion 06-06 (PDF)
(concerning a proposed exclusive arrangement for emergency ambulance services)
05-03-2006
Advisory Opinion 06-05 (PDF)
(concerning a research hospital's practice of providing drugs and supplies to its affiliates for administration to the hospital's patients receiving treatment at the affiliates)
04-27-2006
Advisory Opinion 06-04 (PDF)
(concerning a nonprofit, tax-exempt, charitable corporation’s proposal to provide financially needy Medicare beneficiaries with assistance with premiums and cost-sharing obligations under Medicare Part B, Medicare Part D, Medigap [as hereinafter defined], and Medicare Advantage)
04-18-2006
Advisory Opinion 06-03 (PDF)
(concerning a pharmaceutical company patient assistance program that provides free outpatient prescription drugs to financially-needy Medicare Part D enrollees entirely outside of the Part D benefit)
03-28-2006
Advisory Opinion 06-02 (PDF)
(concerning two proposed programs to manage the delivery of durable medical equipment and orthotics to be offered to physicians by a durable medical equipment and orthotics manufacturer and supplier)
03-27-2006
Advisory Opinion 06-01 (PDF)
(concerning a home health agency’s practice of providing prospective customers with a free preoperative home safety assessment)

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