Policies

Baxano-Conducted Training and Education

Baxano may provide healthcare professionals with training and education on our products and disease states. This may include “hands on” training sessions, cadaver workshops, lectures and presentations.

• Programs and events must be conducted in a setting that is conducive to the effective transmission of information (resort locations, for example, are not acceptable).
• Baxano may provide attendees with modest meals and refreshments
• When necessary, Baxano may pay for reasonable travel and modest lodging costs of Health Care Professionals attending out-of-town programs.
• It is not appropriate for Baxano to pay any expenses for guests of the attending Health Care Professionals.

Third-Party Educational Conferences

Baxano may provide grants to bona fide independent, educational, scientific, and policymaking conferences when the conference sponsor is responsible for selection of program content, faculty educational methods, and materials.

• Baxano can provide funding to the conference sponsor (not individual Health Care Professionals) to support the provision of meals and refreshments for all of the healthcare professional attendees.
• Baxano may make grants to conference sponsors for reasonable honoraria, travel, lodging, and modest meals for healthcare Professionals who are bona fide conference faculty members.
• Baxano may purchase advertisements and lease booth space for Company displays at conferences.

Sales, Promotional and Other Business Meetings

Baxano may conduct these meetings with Health Care Professionals to discuss, for example, product features, sales terms, or contracts.

• Baxano can pay for reasonable travel costs and provide occasional modest meals and refreshments for these meetings (e.g., plant tours or demonstrations of non-portable equipment).
• It is not appropriate for Baxano to pay any expenses for guests of the attending Health Care Professionals.

Consulting Arrangements with Health Care Professionals

Baxano may engage Health Care Professionals to provide bona fide consulting services such as contracts for research, product development, marketing, participation on advisory boards, presentation at Company-sponsored training and other services.

• Consultants must be paid fair market value compensation for performing these services.
• Services must fulfill a legitimate business need (identified and documented in advance) and do not constitute an unlawful inducement (i.e., not based on the volume or value of the consultant’s past, present or anticipated business).
• Consulting agreements must be written.
• Reasonable agreed upon expenses such as travel, modest meals, and lodging can be reimbursed.
• Company-sponsored meals and refreshments provided in conjunction with a consultant meeting must be modest in value and subordinate in time and focus to the primary purpose of the meeting.
• Baxano Sales personnel should not control or unduly influence the decision to engage a particular Health Care Professional as a consultant. Selection should be made on the basis of qualifications and expertise to meet the defined need.

Entertainment and Recreation

To ensure the appropriate focus on and educational/informational exchange and to avoid any appearance of impropriety, Baxano will not pay for any entertainment or recreational activity for any non-employee Health Care Professional. Such activities include, for example, theater, sporting events, golf, skiing, sporting equipment and leisure or vacation trips.

Business Meals

Modest meals may be provided as an occasional business courtesy in conjunction with interactions with Health Care Professionals.

• Meals must be incidental to bona fide presentation of scientific, educational, or business information in a setting that is conducive to the discussion.
• Baxano can provide a meal only to Health Care Professionals who actually attend the meeting. Baxano cannot provide a meal for an entire office staff where everyone does not attend the meeting.
• It is not appropriate for Baxano to pay any expenses for guests of the attending healthcare professionals.

Educational Items and Gifts

Baxano can occasionally provide items to healthcare professionals that benefit patients or serve a genuine educational function.

• These items must be less than $100 (with the exception of medical textbooks or anatomical models).
• Any type of non-educational branded promotional items are prohibited, regardless of their value. Examples include pens, notepads, mugs, and other items that have Baxano’s name, logo or product information.
• Gifts to Health Care Professionals are prohibited, such as cookies, wine, flowers, chocolates, gift baskets, holiday gifts, cash, or cash equivalents.

Coverage, Reimbursement and Health Economic Information

Patient access to Baxano products may be dependent on Health Care Professionals and/or patients having timely and complete coverage, reimbursement and health economic information.

• The Company is allowed to collaborate with Health Care Professionals, patients and organizations representing their interests, to achieve government and commercial payor coverage decisions, guidelines, policies, and adequate reimbursement levels that allow patient access to Baxano products.
• The Company may not interfere with a Health Care Professional’s independent clinical decision-making or provide coverage, reimbursement and health economics support as an unlawful inducement. For example, Baxano must not provide free services that eliminate an overhead or other expense that a Health Care Professional would otherwise have incurred as part of its business operations.
• Baxano cannot suggest mechanisms for billing for services that are not medically necessary, or for engaging in fraudulent practices to achieve inappropriate payment.

Research and Educational Grants and Charitable Donations

Baxano may provide research grants that ultimately benefit patients; provide educational grants to advance medical or public education; and make monetary or product donations for legitimate charitable purposes.

• Grants and donations will not be provided based on the volume or value of purchases made by, or anticipated from, the recipient.
• Sales personnel will not unduly influence the decision of whether a particular Health Care Professional or institution will receive a grant/donation.
• Research grants should have well-defined objectives and milestones and may not be linked to the purchase of Baxano product.
• All grants and donations will be properly documented.

Evaluation and Demonstration Product

Baxano may provide reasonable quantities of products to Health Care Professionals at no charge for evaluation and demonstration purposes.

• The number of free single-use products should not exceed the amount reasonably necessary for the adequate evaluation of the products under the circumstances.
• Multiple-use products provided without transfer of title should be furnished only for a period of time that is reasonable under the circumstances to allow an adequate evaluation. Product should be removed promptly at the conclusion of the evaluation period, unless the Health Care Professional purchases or leases the products.
• Demonstration products are typically unsterilized single-use products used for Health Care Professional and patient awareness, education and training.  Demo products are not intended to be used in patient care and should be identified as “Sample,” “Not for Human Use,” or other suitable designation.