Compliance Agreement
Before submitting, confirm your understanding of the following terms and conditions:
All events must contain a robust agenda including scientific, educational, or business presentations that account for the majority of time of the event.
You may not pay for or provide any entertainment or recreational activity incidental to the event.
All attendees must have a legitimate business interest in the information provided. Participation of non-HCP attendees spouses and guests will result in disciplinary action. In the event a guest is present through no invitation of your own, you may not pay for that individual's costs; these costs must be paid for by the individual on a separate tab.
You may not pay for or provide more than 3 alcoholic drinks per HCP throughout the duration of the event. If possible, utilize a drink ticketing system to ensure compliance.
All meals must be modest and reasonably priced and may never exceed $150 pp, including tax and tip. No meals may be provided for virtual events or any event where P28 personnel is not present.
Within 7 days after the event, you are responsible for submitting a complete and legible sign-in sheet for all attendees when F&B is provided. You are welcome to create your own so long as it contains first and last name and NPI number (or title if no NPI). You are also responsible for producing an itemized receipt within that same time frame.
You are responsible for ensuring that a full and accurate CMS report relevant to the event is submitted by either you or the individual who submitted payment.
Failure to provide the documentation required by items 6 or 7 will result in $0 reimbursement or 100% commission reduction of the cost of the event as well as potential further discipline at the discretion of the Chief Compliance Officer.
Request for HCP consultant assistance is not a guarantee; the determination of whether the request is compliant and feasible will be made by internal HQ personnel. Salespeople may not request services from an HCP.
If you have any additional information or questions in regards to a specific event, or the event submission process, please contact Events & Tradeshow Manager Kristin Grunewald (kgrunewald@paragon28.com).