Common use of Medical Education Grant Activities Clause in Contracts

Medical Education Grant Activities. GSK represents that it provides grants for medical education of HCPs on a limited basis and that it provides such grants only to educational providers (including academic medical centers, hospital or delivery systems, or professional medical associations that represent HCPs who deliver patient care) that satisfy pre-set criteria established by GSK. Potentially eligible educational providers are selected annually and invited to submit grant proposals for a future fiscal year. GSK represents that it does not provide funding to any commercial providers of medical education. GSK’s Medical Affairs organization reviews the grant proposals from the potential providers and makes recommendations for approval based on objective criteria, compliance policies and procedures, and budget availability. GSK represents that its commercial organization (including the sales and marketing departments) has no involvement in, or influence over, the review and approval of medical education grants. GSK shall continue the medical education grant process described above (or an equivalent process) throughout the term of the CIA, and shall notify the OIG in writing at GlaxoSmithKline LLC Corporate Integrity Agreement least 60 days prior to the implementation of any new system subsequent to the Effective Date. To the extent not already accomplished, within 120 days after the Effective Date, GSK shall establish a Grants Monitoring Program through which it shall conduct audits for each Reporting Period of at least 10 medical education grants for the first Reporting Period and 5 medical education grants for subsequent Reporting Periods. The Grants Monitoring Program shall select grants for review both on a risk-based targeting approach and on a sampling approach. GSK Monitoring Personnel conducting the Grants Monitoring Program shall review proposal documents (including grant requests), approval documents, contracts, payments and materials relating to the grant office’s review of the requests, and documents and materials relating to the grants and any events or activities funded through the grants in order to assess whether the activities were conducted in a manner consistent with GSK’s Policies and Procedures. Results from the Grant Monitoring Programs, including the identification of potential violations of policies, shall be compiled and reported to the Compliance Officer (or compliance personnel designee) for review and follow-up as appropriate.

Medical Education Grant Activities. GSK represents Prior to the Effective Date, Daiichi established a grants management system that it provides is the exclusive mechanism though which requestors may request or be awarded grants for independent medical education of HCPs on a limited basis and that it provides such grants only to educational providers (including academic medical centersgrants, hospital or delivery systems, or professional medical associations that represent HCPs who deliver patient care) that satisfy pre-set criteria established by GSK. Potentially eligible educational providers are selected annually and invited to submit other grant proposals for a future fiscal year. GSK represents that it does not provide funding to any commercial providers of medical education. GSK’s Medical Affairs organization reviews the grant proposals from the potential providers and makes recommendations for approval based on objective criteria, compliance policies and proceduresactivities, and budget availabilitycharitable contributions supported by Daiichi. GSK represents that its commercial organization (including the Daiichi’s sales and marketing departments) has personnel do not and shall continue to have no involvement in, or influence over, the review and approval of medical education grantsgrants or charitable contribution requests. GSK Grant and charitable contribution requests shall be submitted through a centralized grants management system and processed in accordance with standardized, objective criteria developed by Daiichi (such as based upon the qualifications of the requestor, or the quality of the program funded by the grant.) In addition, the grants or charitable contributions shall be provided only pursuant to a written agreement with the funding recipient, and if payments to the funding recipient are consistent with the written agreement. Daiichi shall continue the medical education grant and charitable contribution process described above (or an equivalent process) throughout the term of the CIA, and shall notify the OIG in writing at GlaxoSmithKline LLC Corporate Integrity Agreement least 60 days prior to the implementation of any new system subsequent to the Effective Date. To the extent not already accomplished, accomplished and within 120 90 days after the Effective Date, GSK Daiichi shall establish a Grants Monitoring Program through which it shall conduct audits for each Reporting Period of at least 10 30 medical education grants for the first Reporting Period and 5 medical education grants for subsequent Reporting Periodsgrants. The Grants Monitoring Program shall select grants for review both on a risk-based targeting approach and on or a random sampling approach. GSK Monitoring Personnel conducting the Grants Monitoring Program shall review proposal documents (including grant requests), approval documents, contracts, payments and materials relating to the grant officemanagement system’s review of the requests, and documents and materials relating to the grants and any events or activities funded through the grants in order to assess whether the activities were conducted in a manner consistent with GSKDaiichi’s Policies and Procedures. Results from the Grant Grants Monitoring Programs, including the identification of potential violations of policies, shall be compiled and reported to the Compliance Officer (or compliance personnel designee) for review and follow-up as appropriate.