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Patient Education Programs

Payments for Patient Education Programs must reflect Fair Market Value (FMV) and should not replace or subsidize expenses that are part of a customer's routine costs for delivering healthcare services or managing their business operations.

Patient Education Programs include a range of patient reminder communications designed to enhance patient care and provide information related to Bausch + Lomb’s business activities, such as disease education and patient adherence. Bausch + Lomb partners with managed care plans to help distribute this information. Payments for Patient Education Programs must align with Fair Market Value (FMV) and be properly documented in a timely manner.

Quick Tips:

  • Bausch + Lomb may not offer product discounts in exchange for a Customer agreement to engage in a Patient Education Program. Patient Education Programs

Bausch + Lomb Colleagues should not discuss Patient Education Programs at the same time that Bausch + Lomb is negotiating pricing terms or other commercial arrangements.

Acceptable Patient Education Programs

Bausch + Lomb Colleagues may engage contractors to provide bona fide commercial services as part of a Patient Education Program, but only with prior written approval from the Bausch + Lomb Compliance and Legal Departments. Examples of acceptable Patient Education Programs include:

  • Mailing Bausch + Lomb-prepared and approved disease management or patient education materials to healthcare professionals or patients.
  • Sending medication compliance reminders to patients to encourage prescription fills or refills for chronic conditions.
  • Providing “patient information cards” to individuals using a Bausch + Lomb product for the first time.
  • Sponsoring a one-time mailing to announce the addition of a Bausch + Lomb product to a formulary.

Patient Education Programs must not replace or subsidize activities that are part of a customer’s normal costs for delivering healthcare services or operating their business.

This policy applies to each payment made for a Patient Education Program, even if multiple programs are managed under a single contract.

Unacceptable Patient Education Programs

It is against Bausch + Lomb policy to engage in any Patient Education Program in exchange for a product discount offered by Bausch + Lomb.

Examples of unacceptable Patient Education Programs include those that are:

  • Conducted by the payer in exchange for a product discount.
  • Provided in return for performing marketing activities.
  • Paid for at an inflated cost.
  • Intended to replace or subsidize expenses that are part of the customer’s normal business operations.
  • Designed to downplay or minimize risk and safety information.
  • Aimed at encouraging patients to refill prescriptions without advising them to consult their physician with any questions about the product.
  • Interfering with the payer’s independent clinical judgment or intended to switch patients from competitor therapies.
  • Intended to induce the customer to purchase, prescribe, or recommend Bausch + Lomb products.

Service Negotiations

Please consult the Service Arrangements section of this Guide for further guidance.