Common use of Medical Education Grant Activities Clause in Contracts

Medical Education Grant Activities. To the extent not already accomplished, within 120 days after the Effective Data, BIPI shall establish a Grants Management System as the exclusive mechanism through which requestors may seek or be awarded grants for independent medical education activities. The Grants Management System shall ensure that the BIPI sales and marketing departments have no involvement in, or influence over, the review and approval of medical education grants. To the extent not already accomplished, within 120 days after the Effective Data, BIPI shall develop a system for grant submission and processing by a centralized office which is not part of the sales or marketing division. BIPI 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 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, BIPI shall establish a Grants Monitoring Program through which it shall conduct audits for each Reporting Period of at least 30 medical education grants. The Grants Monitoring Program shall select grants for review both on a risk-based targeting approach and on a sampling approach. 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 BIPI’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 Ethics and Compliance Department for review and follow-up as appropriate.

Medical Education Grant Activities. To the extent not already accomplished, within a. Within 120 days after the Effective DataDate, BIPI USWM shall establish a Grants Management System as grants management system which shall be the exclusive mechanism through though which requestors may seek request or be awarded grants for independent medical education grants, other grant activities, and charitable contributions supported by USWM. The Grants Management System shall ensure that the BIPI USWM’s sales and marketing departments have no involvement personnel shall not be involved in, or influence over, the review and approval of medical education grantsgrants or charitable contribution requests. To Grant and charitable contribution requests shall be processed in accordance with standardized, objective criteria developed by USWM (such as based upon the extent not already accomplished, within 120 days after the Effective Data, BIPI shall develop a system for grant submission and processing by a centralized office which is not part qualifications of the sales requestor, or marketing division. BIPI shall continue the medical education grant process described above (or an equivalent process) throughout the term quality of the CIAprogram 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 shall notify the OIG in writing at least 60 days prior if payments to the implementation of any new system subsequent to funding recipient are consistent with the Effective Date. To the extent not already accomplished, within written agreement.‌ b. Within 120 days after the Effective Date, BIPI USWM shall establish a Grants Monitoring Program through which it shall conduct audits for each Reporting Period of at least 30 3 medical education grants. The Grants Monitoring Program shall select grants for review both on either a risk-based targeting approach and on or a random sampling approach. 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 the‌ Corporate Integrity Agreement – USWM grants and any events or activities funded through the grants in order to assess whether the activities were conducted in a manner consistent with BIPIUSWM’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 Ethics and Compliance Department Officer (or compliance personnel designee) for review and follow-up as appropriateappropriate.‌ USWM shall continue the grant and charitable contribution process described above (or an equivalent process) throughout the term of the CIA and shall notify OIG in writing at least 60 days prior to the implementation of any new system after the Effective Date.

Medical Education Grant Activities. To the extent not already accomplished, within Within 120 days after the Effective Data, BIPI Baxano Surgical shall establish a Grants Management System grants management system as the exclusive mechanism through which requestors may seek or be awarded grants for independent medical education activities. The Grants Management System grants management system shall ensure that the BIPI Baxano Surgical sales and marketing departments have no involvement in, or influence over, the review and approval of medical education grants. To the extent not already accomplished, within 120 days after the Effective Data, BIPI Baxano Surgical shall develop a system for grant submission and processing by a centralized office which is not part of the sales or marketing divisiondivisions. BIPI Baxano Surgical 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 least 60 days prior to the implementation of any new system subsequent to the Effective Date. To the extent not already accomplished, within Within 120 days after the Effective Date, BIPI Baxano Surgical shall establish a Grants Monitoring Program through which it shall conduct audits for each Reporting Period of at least 30 10 percent of medical education grants. The Grants Monitoring Program shall select grants for review both on a risk-based targeting approach and on a sampling approach. Monitoring Personnel Baxano Surgical compliance 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 BIPIBaxano Surgical’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 Ethics and Compliance Department for review and follow-up as appropriate.

Medical Education Grant Activities. To the extent not already accomplished, within Within 120 days after the Effective DataDate, BIPI Novartis and the Novartis Affiliates shall establish a Grants Management System as grants management systems which shall be the exclusive mechanism through though which requestors may seek request or be awarded grants for independent medical education grants, other grant activities, and non-patient assistance program charitable contributions supported by Novartis. The Grants Management System shall ensure that the BIPI Novartis’ sales and marketing departments personnel shall have no involvement in, or influence over, the review and approval of medical education grantsgrants or charitable contribution requests. To Grant and charitable contribution requests shall be submitted through the extent not already accomplishedcentralized grants management systems and processed in accordance with standardized, within 120 days after objective criteria developed by Novartis (such as based upon the Effective Data, BIPI shall develop a system for grant submission and processing by a centralized office which is not part qualifications of the sales requestor, or marketing divisionthe 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. BIPI Novartis 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 least 60 days prior to the implementation of any new system subsequent to the Effective Date. To the extent not already accomplished, within Within 120 days after the Effective Date, BIPI Novartis shall establish a Grants Monitoring Program through which it shall conduct audits for each Reporting Period of at least 30 medical education grants. The Grants Monitoring Program shall select grants for review both on either a risk-based targeting approach and on or a random sampling approach. 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 BIPI’s Novartis’ 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 Ethics and Chief Compliance Department Officer (or compliance personnel designee) for review and follow-up as appropriate.