(2.2.7) Illustrative Education Item or Patient Benefit Item Best Practices

Transcript

1 by the Code. Do not provide. The item is prohibited of the AdvaMed Code. [Section IX, FAQ 38, 40, 41, 42] Raffling off items (or giving such items away All items capable of non-educational, non- player); anniversary, death, etc.); and recognize HCP life events (wedding, birth, Non-educational branded promotional items Giving flowers, fruit baskets, etc. to cash/cash equivalents; otherwise be prohibited. patient-related use (e.g., iPod, iPad, DVD at a tradeshow) to HCPs that would chocolates, gift baskets, holiday gifts, or Gifts such as wine, flowers, cookies, (e.g., pens, notepads, mugs); l items or patient benefit items to Health Care Examples of prohibited gifts include: Items not provided to HCPs are outside the scope providers or products. Medicare Beneficiaries to induce the selection of companies must undertake their own analysis of the Note: For items provided directly to the patient, federal prohibitions against offering remuneration to No No No Yes Yes Yes tion purposes, which is addressed in Section XII of the Code, nor to the AdvaMed Code for definitions of HCP, Company, and other [FAQ 42] [Section IX] [Section IX] and anatomical models? l branded promotional item? No No No Yes Yes provided. ts for evaluation and demonstra The item is [Section IX] [Section IX] item and may be a permitted educational an HCP? related purpose of the HCP? Is the item to be provided to educational function for the HCP? Does providing the item to the HCP serve a genuine Is the item capable of a non-educational, non-patient- except for medical textbooks Does the item have a fair market value of less than $100, Is the item offered as an unlawful inducement? Is the item a non-educationa supplies, etc. [Section IX, FAQ 42] are: DVD players, MP3 players, iPod, iPad, scrubs, office Note: Examples of non-educational, non-patient-related items to ensure they are not offered as an unlawful inducement. Note: The Code recommends that companies establish [FAQ 42] appropriate safeguards regarding the provision of such items educational branded promotional item, even if the item is of [Section IX] of patients. Examples of non-educational branded promotional items include: pens, notepads, mugs, etc. minimal value and related to the HCP’s work or for the benefit Note: A Company may not give an HCP any type of non- te practice of providing produc hics. Companies are not obligated to follow this chart. Refer No Yes Yes Yes [FAQ 42] [Section IX] [Section IX, FAQ 42] No No Yes The item is be provided. a permitted patient benefit item and may The following chart is intended to provide a summary of the existing AdvaMed Code as it relates to the provision of educationa related purpose of the HCP? educational brochures)? Is the item intended for the patient (e.g., starter kit, Is the item capable of a non-educational, non-patient- Is the item offered as an unlawful inducement? [FAQ 42] to ensure they are not offered as an unlawful inducement. appropriate safeguards regarding the provision of such items Note: The Code recommends that companies establish are: DVD players, MP3 players, iPod, iPad, scrubs, office Note: Examples of non-educational, non-patient-related items supplies, etc. [Section IX, FAQ 42] terms. should it be utilized in lieu of the complete AdvaMed Code of Et Professionals (HCPs). It is not intended to address the legitima Purpose/Scope: Section IX: Educational Items; Prohibition on Gifts Illustrative Educational Item or Patient Benefit Item Best Practices

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