STATE OF CALIFORNIA COMPLIANCE PROGRAM DECLARATION
In accordance with the requirements of California Health & Safety Code §§ 119400-119402, we have established an annual dollar limit of $1,500 for certain spending on individual medical or healthcare professionals licensed in California. We include in this dollar limit the value of educational items and meals provided to healthcare professionals in connection with business and educational discussions with those individuals. The annual spending limit set forth in this declaration does not include the value of:
- financial support for continuing medical education forums;
- financial support for health education scholarships; and
- payments made for legitimate professional services provided by a healthcare professional so long as the amount paid does not exceed the fair market value of the services provided.
This dollar limit represents a spending maximum and not an average or goal. We reserve the right to change this limit at any time.
We also adhere to global transparency laws and regulations, including Section 6002 of the Patient Protection and Affordable Care Act, which requires us to report payments and transfers of value made to certain healthcare professionals and teaching hospitals.
SEPTEMBER 1, 2021 CALIFORNIA DECLARATION OF COMPLIANCE
To the best of our knowledge and based on our good faith understanding of the statutory requirements, we declare that we are in compliance with our compliance program and the requirements of California Health & Safety Code §§ 119400-119402 in all material respects.
This declaration is not intended and should not be construed to imply that we have not identified any individual instances in which an employee has or may have violated one or more provisions of our compliance program. In such situations, we take reasonable and appropriate remedial or corrective actions in a manner consistent with our compliance program.
Copies of this declaration and a description of our compliance program may be obtained by contacting our Compliance Department at email@example.com or our corporate headquarters at (617) 649-8600.