DEPARTMENT: Ethics and Compliance / POLICY DESCRIPTION: Vendor-Promotional Training and Business Associate-Sponsored Seminars
PAGE: 2 of 2 / REPLACES POLICY DATED: 4/1/1998; 12/15/1999; 9/30/2002
EFFECTIVE DATE: November 15, 2006 / REFERENCE NUMBER: EC.007
APPROVED BY: Ethics and Compliance Policy Committee
SCOPE: All Company-affiliated facilities including, but not limited to, hospitals, ambulatory surgery centers, home health agencies, physician practices, service centers and all Corporate Departments.
PURPOSE: To establish the parameters surrounding acceptance of vendor-promotional training and business associate-sponsored seminars.
POLICY:
1.  “Vendor-promotional training” is defined as training or education provided by any person or entity for the purpose of promoting its products or services.
a.  It includes travel paid by a vendor for facility-personnel to observe the vendor’s product in a setting where the product is already installed or otherwise designed to showcase the product(s).
b.  It does not include training provided under a contract with the Company or by a contractor to facilitate use of products or services it furnishes under an existing contract with the Company.
c.  Vendor-promotional training, including travel and lodging, may be accepted free of charge when the business value to our organization outweighs any recreational or entertainment value of the training event, provided that the appropriate approvals are obtained in advance.
2.  “Business associate-sponsored seminars” refers to seminars, conferences, user review group meetings or other educational sessions sponsored and hosted directly by a business associate (i.e., someone doing or seeking to do business with HCA or an HCA-affiliated entity).
a.  It does not include offers from business associates to pay the registration fees, travel, lodging and/or meals for HCA employees to attend conferences or seminars sponsored by a person or entity other than the inviting business associate.
b.  Provided that the appropriate approvals are obtained in advance, invitations to attend business associate-sponsored seminars, which may include free or reduced registration fees, travel, lodging and meals, may be accepted only when:
i.  the event is not limited to HCA or HealthTrust Purchasing Group member participants (e.g., individuals from various companies and organizations have been invited to attend the event);
ii.  no fee is charged to any invitee or, if a fee is charged for some portion of the event or a reduction given, the same fee is charged or same reduction is given to each invitee; and
iii.  the value to our organization outweighs any recreational or entertainment value of the educational event.
PROCEDURE:
An employee, other than a Corporate Senior Vice President, who receives an invitation to attend vendor-promotional training or a business associate-sponsored seminar, which may include travel, lodging or modest entertainment expenses must obtain the approval of his/her supervisor and the facility ECO before accepting the invitation. A Corporate Senior Vice President (SVP) must obtain the approval of the SVP and Chief Ethics and Compliance Officer prior to accepting such an invitation.
1.  The supervisor and facility ECO (or Corporate SVP and Chief Ethics and Compliance Officer) will assess the situation, including making a calculation as to the amount of time to be spent on substantive matters as compared to the amount of time spent in recreational or entertainment activities. The amount of time engaged in substantive matters must predominate in order for acceptance to be permitted. The employee will provide the supervisor (or SVP) with sufficient information (such as a course description and/or the letter of invitation) for the supervisor and ECO (or SVP) to make the assessments required under this policy.
2.  If the ECO and supervisor determine that attendance is preferred despite the entertainment portion predominating over substantive, the ECO must receive the advance written approval of the SVP and Chief Ethics and Compliance Officer.
3.  If attendance at a vendor-promotional training event or business associate-sponsored seminar involves travel outside the continental United States or lodging in excess of two nights, the employee must also receive approval from the SVP and Chief Ethics and Compliance Officer prior to accepting the invitation.
REFERENCES:
Code of Conduct, Business Courtesies Section.

5/2007