There are occasions when direct communication with patients or consumers, including caregivers, can enhance healthcare outcomes. As an organization, we honor the doctor-patient relationship and uphold the privacy rights of patients. It is essential that all interactions with patients are conducted appropriately and in full compliance with applicable laws and regulations.
There are occasions when direct communication with patients or consumers, including caregivers, can enhance healthcare outcomes. As an organization, we honor the doctor-patient relationship and uphold the privacy rights of patients. It is essential that all interactions with patients are conducted appropriately and in full compliance with applicable laws and regulations.
Quick Tips:
Bausch + Lomb Colleagues may encounter patients or consumers in healthcare professional (HCP) waiting rooms. If approached, it is appropriate for colleagues to introduce themselves; however, they must not initiate or engage in discussions about products or related information with consumers in these settings.
Bausch + Lomb colleagues are not permitted to participate in or attend patient or caregiver-sponsored support groups.
Those supporting pharmaceutical or Medical Device products must not demonstrate the use of drugs or devices to patients or consumers in any setting.
Additionally, colleagues should refrain from commenting on the personal or professional conduct of any healthcare professionals when in the presence of patients or caregivers.
Bausch + Lomb Colleagues may encounter patients or consumers in healthcare professional (HCP) waiting rooms. If approached, it is appropriate for colleagues to introduce themselves; however, they must not initiate or engage in discussions about products or related information with consumers in these settings.
Bausch + Lomb colleagues are not permitted to participate in or attend patient or caregiver-sponsored support groups.
Those supporting pharmaceutical or Medical Device products must not demonstrate the use of drugs or devices to patients or consumers in any setting.
Additionally, colleagues should refrain from commenting on the personal or professional conduct of any healthcare professionals when in the presence of patients or caregivers.
Bausch + Lomb colleagues may take part in health-related patient or consumer events organized by healthcare institutions (HCIs), such as hospitals, or other corporate-approved organizations, provided that the Marketing team has an approved corporate strategy for engaging in these activities.
At consumer events where there is an opportunity to interact with consumers:
All patient or consumer questions regarding products should be directed to their own healthcare professionals (HCPs). Consumers should not be referred to specific HCPs but may be guided to a brand’s “Find a Doctor” website.
Bausch + Lomb colleagues may take part in health-related patient or consumer events organized by healthcare institutions (HCIs), such as hospitals, or other corporate-approved organizations, provided that the Marketing team has an approved corporate strategy for engaging in these activities.
At consumer events where there is an opportunity to interact with consumers:
All patient or consumer questions regarding products should be directed to their own healthcare professionals (HCPs). Consumers should not be referred to specific HCPs but may be guided to a brand’s “Find a Doctor” website.
Direct-to-Consumer (DTC) advertising refers to promotional activities conducted by or on behalf of Bausch + Lomb (including its subsidiaries and Affiliates) that focus on a product or disease state and are aimed at the general public through lay media in the United States, rather than targeting healthcare professionals (HCPs) or patients actively seeking treatment. In carrying out DTC advertising, Bausch + Lomb complies with all relevant regulations, the PhRMA Guiding Principles on Direct-to-Consumer Advertising About Prescription Medicines, and established promotion standards. Our DTC communications are designed to:
While any authorized HCP can prescribe or administer Bausch + Lomb products based on medical judgment, it can be beneficial for patients to know which professionals have experience with or training on a specific product. Engaging consumers through multimedia DTC promotion may increase their interaction and communication.
As a result, Bausch + Lomb colleagues may encounter or handle Personal Data, including protected health information (PHI). Please refer to the "Access to Protected Health Information" section below for guidance on safeguarding the privacy and confidentiality of PHI.
Direct-to-Consumer (DTC) advertising refers to promotional activities conducted by or on behalf of Bausch + Lomb (including its subsidiaries and Affiliates) that focus on a product or disease state and are aimed at the general public through lay media in the United States, rather than targeting healthcare professionals (HCPs) or patients actively seeking treatment. In carrying out DTC advertising, Bausch + Lomb complies with all relevant regulations, the PhRMA Guiding Principles on Direct-to-Consumer Advertising About Prescription Medicines, and established promotion standards. Our DTC communications are designed to:
While any authorized HCP can prescribe or administer Bausch + Lomb products based on medical judgment, it can be beneficial for patients to know which professionals have experience with or training on a specific product. Engaging consumers through multimedia DTC promotion may increase their interaction and communication.
As a result, Bausch + Lomb colleagues may encounter or handle Personal Data, including protected health information (PHI). Please refer to the "Access to Protected Health Information" section below for guidance on safeguarding the privacy and confidentiality of PHI.
Bausch + Lomb may engage patients or consumers as Consultants for legitimate business purposes. These patient or customer consultants should possess relevant experience with a specific disease or its treatment to provide the required consulting services. All engagements must be governed by a written contract clearly outlining tasks, responsibilities, compensation, and confidentiality terms. Fees and expenses must be reasonable and reflect Fair Market Value for the services rendered.
Consulting arrangements with patients should not be used primarily for product promotion. However, insights gained, or services provided through these interactions may be utilized to support marketing efforts and/or promotional materials.
When beginning discussions with potential consultants, appropriate patient consent must be obtained.
If a patient or consumer with a social media presence is engaged or their services are requested on social media, any related content must be reviewed by the appropriate promotional review committee and include necessary disclosures. Additionally, the patient or consumer should receive proper training.
Bausch + Lomb may engage patients or consumers as Consultants for legitimate business purposes. These patient or customer consultants should possess relevant experience with a specific disease or its treatment to provide the required consulting services. All engagements must be governed by a written contract clearly outlining tasks, responsibilities, compensation, and confidentiality terms. Fees and expenses must be reasonable and reflect Fair Market Value for the services rendered.
Consulting arrangements with patients should not be used primarily for product promotion. However, insights gained, or services provided through these interactions may be utilized to support marketing efforts and/or promotional materials.
When beginning discussions with potential consultants, appropriate patient consent must be obtained.
If a patient or consumer with a social media presence is engaged or their services are requested on social media, any related content must be reviewed by the appropriate promotional review committee and include necessary disclosures. Additionally, the patient or consumer should receive proper training.
Generally, Bausch + Lomb is not classified as a Covered Entity and therefore is not directly regulated by HIPAA. However, many colleagues regularly interact with Covered Entities (such as clinical sites, pharmacies, and physicians) that are directly subject to HIPAA regulations.
All Bausch + Lomb colleagues are responsible for protecting the privacy and confidentiality of any Protected Health Information (PHI) they may encounter during their employment or interactions with Covered Entities:
Bausch + Lomb should decline all requests to sign a Business Associate Agreement, as the company does not perform services or Functions involving PHI on behalf of a Covered Entity. Instead, colleagues asked to sign such agreements should provide the requester with the standard approved Bausch + Lomb Business Associate Letter. If a colleague is requested to sign a confidentiality agreement due to potential contact with PHI, they should contact Bausch + Lomb’s Credentialing Office for guidance and review.
Generally, Bausch + Lomb is not classified as a Covered Entity and therefore is not directly regulated by HIPAA. However, many colleagues regularly interact with Covered Entities (such as clinical sites, pharmacies, and physicians) that are directly subject to HIPAA regulations.
All Bausch + Lomb colleagues are responsible for protecting the privacy and confidentiality of any Protected Health Information (PHI) they may encounter during their employment or interactions with Covered Entities:
Bausch + Lomb should decline all requests to sign a Business Associate Agreement, as the company does not perform services or Functions involving PHI on behalf of a Covered Entity. Instead, colleagues asked to sign such agreements should provide the requester with the standard approved Bausch + Lomb Business Associate Letter. If a colleague is requested to sign a confidentiality agreement due to potential contact with PHI, they should contact Bausch + Lomb’s Credentialing Office for guidance and review.
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