Healthcare organizations play a key role in influencing patient therapy and facilitating access to Bausch + Lomb products. It is appropriate for Bausch + Lomb Colleagues to educate HCOs about our products and approved programs to help ensure patient access.
Bausch + Lomb may enter into contractual agreements with HCOs, including service arrangements and product discount contracts, which must comply with all relevant laws, regulations, and ethical standards. For detailed information, refer to the “Service Arrangements” and “Product Discount and/or Rebate Arrangements” sections.
Healthcare organizations play a key role in influencing patient therapy and facilitating access to Bausch + Lomb products. It is appropriate for Bausch + Lomb Colleagues to educate HCOs about our products and approved programs to help ensure patient access.
Bausch + Lomb may enter into contractual agreements with HCOs, including service arrangements and product discount contracts, which must comply with all relevant laws, regulations, and ethical standards. For detailed information, refer to the “Service Arrangements” and “Product Discount and/or Rebate Arrangements” sections.
Interactions between sales colleagues and specific HCO types (e.g., retail or specialty pharmacies, home infusion centers) should align with approved marketing strategies. Communications with HCOs should focus on providing appropriate product education, disease state awareness, and access information. Sales colleagues must only discuss on-label uses of Bausch + Lomb products and use company-approved materials consistent with policies on “Appropriate Promotional Activity” and “Promotional Materials.”
Interactions between sales colleagues and specific HCO types (e.g., retail or specialty pharmacies, home infusion centers) should align with approved marketing strategies. Communications with HCOs should focus on providing appropriate product education, disease state awareness, and access information. Sales colleagues must only discuss on-label uses of Bausch + Lomb products and use company-approved materials consistent with policies on “Appropriate Promotional Activity” and “Promotional Materials.”
If healthcare professionals employed by HCOs request product information that falls outside approved labeling, sales or commercial colleagues should not provide answers but instead refer such inquiries to Medical Information Services or the appropriate Medical department.
It is inappropriate for Bausch + Lomb colleagues to request or obtain blank, voided, or practice prescriptions from offices, even for clerical purposes. Likewise, submitting test claims (e.g., dummy scripts), even if intended to be canceled, is prohibited. Colleagues must not pressure or induce pharmacists or pharmacy staff to submit such test scripts.
If healthcare professionals employed by HCOs request product information that falls outside approved labeling, sales or commercial colleagues should not provide answers but instead refer such inquiries to Medical Information Services or the appropriate Medical department.
It is inappropriate for Bausch + Lomb colleagues to request or obtain blank, voided, or practice prescriptions from offices, even for clerical purposes. Likewise, submitting test claims (e.g., dummy scripts), even if intended to be canceled, is prohibited. Colleagues must not pressure or induce pharmacists or pharmacy staff to submit such test scripts.
Bausch + Lomb colleagues must always maintain patient confidentiality and are prohibited from accessing protected health information (PHI) during interactions with HCOs. For instance, sales colleagues may not use electronic health record (EHR) systems to identify patients, track prescriptions at pharmacies, or collect HCP or patient information for purposes such as product access support, Savings Programs, or availability determination.
Bausch + Lomb colleagues must always maintain patient confidentiality and are prohibited from accessing protected health information (PHI) during interactions with HCOs. For instance, sales colleagues may not use electronic health record (EHR) systems to identify patients, track prescriptions at pharmacies, or collect HCP or patient information for purposes such as product access support, Savings Programs, or availability determination.
When discussing product availability, sales colleagues should not direct customers, including HCPs, to specific pharmacies or pharmacy chains. However, if products have limited or controlled availability, they may inform customers about pharmacies where the product is stocked.
Asking HCP office staff which pharmacies patients use may be appropriate to help allocate educational and access resources effectively. Sales colleagues may use pharmacy data to allocate resources but should not discuss or share pharmacy data—such as volume or stocking information—with others.
Sales colleagues are not permitted to contact HCOs, specialty pharmacies, or reimbursement service vendors on behalf of customers or patients to resolve access or reimbursement issues.
When discussing product availability, sales colleagues should not direct customers, including HCPs, to specific pharmacies or pharmacy chains. However, if products have limited or controlled availability, they may inform customers about pharmacies where the product is stocked.
Asking HCP office staff which pharmacies patients use may be appropriate to help allocate educational and access resources effectively. Sales colleagues may use pharmacy data to allocate resources but should not discuss or share pharmacy data—such as volume or stocking information—with others.
Sales colleagues are not permitted to contact HCOs, specialty pharmacies, or reimbursement service vendors on behalf of customers or patients to resolve access or reimbursement issues.
Generally, sales colleagues should not engage in business-related discussions with HCOs. However, certain Bausch + Lomb field personnel, such as Commercial Managed Markets Account Managers or Business Advisors/Reimbursement Specialists, who are trained and authorized for such interactions, may engage with appropriate HCO management. Compliance should review roles and responsibilities concerning business discussions.
Generally, sales colleagues should not engage in business-related discussions with HCOs. However, certain Bausch + Lomb field personnel, such as Commercial Managed Markets Account Managers or Business Advisors/Reimbursement Specialists, who are trained and authorized for such interactions, may engage with appropriate HCO management. Compliance should review roles and responsibilities concerning business discussions.
Business-related discussions may cover contractual negotiations, pricing (excluding WAC or NDC changes), patient access, service issues, business conditions, formulary coverage trends, and market approaches by health plans and PBM PayFrs. Authorized field colleagues must use approved company resources for these discussions.
Discussions with HCOs must not involve offsetting or defraying operating costs or providing financial value to HCOs.
Sales colleagues should not ask or recommend that HCOs conduct business on Bausch + Lomb’s behalf, such as following HCO patient adherence protocols.
Field colleagues may not participate in joint customer calls with representatives of Third-Party companies, including specialty pharmacies or home infusion centers, nor share customer target lists, unless part of a corporation-approved program (e.g., co-promotion).
Refer to the “Service Arrangements” and “Commercial Contractual Arrangements” sections for more information.
Business-related discussions may cover contractual negotiations, pricing (excluding WAC or NDC changes), patient access, service issues, business conditions, formulary coverage trends, and market approaches by health plans and PBM PayFrs. Authorized field colleagues must use approved company resources for these discussions.
Discussions with HCOs must not involve offsetting or defraying operating costs or providing financial value to HCOs.
Sales colleagues should not ask or recommend that HCOs conduct business on Bausch + Lomb’s behalf, such as following HCO patient adherence protocols.
Field colleagues may not participate in joint customer calls with representatives of Third-Party companies, including specialty pharmacies or home infusion centers, nor share customer target lists, unless part of a corporation-approved program (e.g., co-promotion).
Refer to the “Service Arrangements” and “Commercial Contractual Arrangements” sections for more information.
Bausch + Lomb colleagues must respect and follow HCO policies regarding access and interactions. All HCO policies must be observed unless otherwise directed by the HCO account. It is best practice to request and understand a new HCO’s policies and restrictions concerning pharmaceutical representative interactions before engagement.
Bausch + Lomb may have additional account-specific guidelines (e.g., national accounts). Colleagues affected by these guidelines must adhere to the account’s solicitation and engagement rules.
Colleagues must also comply with all regulations for engaging government employees, including conditions at VA hospitals and other government institutions, on both federal and institutional levels. For more details, see the “Interactions with Government Institutions and Employees” section.
Colleagues are not authorized to sign HCO access contracts or other agreements, including Business Associate Agreements, without prior review by the Credentialing Office.
Bausch + Lomb colleagues must respect and follow HCO policies regarding access and interactions. All HCO policies must be observed unless otherwise directed by the HCO account. It is best practice to request and understand a new HCO’s policies and restrictions concerning pharmaceutical representative interactions before engagement.
Bausch + Lomb may have additional account-specific guidelines (e.g., national accounts). Colleagues affected by these guidelines must adhere to the account’s solicitation and engagement rules.
Colleagues must also comply with all regulations for engaging government employees, including conditions at VA hospitals and other government institutions, on both federal and institutional levels. For more details, see the “Interactions with Government Institutions and Employees” section.
Colleagues are not authorized to sign HCO access contracts or other agreements, including Business Associate Agreements, without prior review by the Credentialing Office.
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