Policy

External presentations made by Company associates that involve the offering of Continuing Education Credits must be within the guidelines set forth below.

General Information

Educational offerings to individuals outside the Company are not prohibited. Such presentations must be reviewed and authorized by management to prevent the loss of proprietary information.

Educational offerings that provide for the distribution of continuing education units or credits (“CEU”) to individuals that may be in a position to refer to the organization may be considered an inappropriate act. To the extent any item has value and is offered to someone in a position to refer patients to the Company at no charge, such an act violates the Company’s compliance program.

If an associate of the Company would like to provide educational presentations to individuals outside the Company, the following options are available:

1.  An associate may provide approved educational presentations after being authorized by the associate’s up-line manager if the presentation(s) do not include the distribution or availability of CEU’s.

2.  The associate may offer CEU’s attached to approved presentations if the presentation is being made to the general public and in accordance with the terms below.

  1. A community notice must be made in a media accessible to the general public, i.e. community bulletin board, web posting, or print media.
  2. The presentation must be held at a Company location or an off-site location such as a public meeting room or hotel conference room. The presentation may not be held at a facility or institution in a position to refer patients to the Company.
  3. Invitations to the presentation may be distributed but no individuals are to be excluded or prevented from attending the presentation.

3.  An associate may offer CEU’s attached to approved presentations to individuals or employees of a referring facility or institution so long as the Company is compensated for the CEU credit(s).

  1. Fair market value for the CEU offered must be charged. Fair market value is obtained by determining the local market price paid for the content and time offered by the CEU in question. For example, a one-hour CEU has nominal value whereas an 8 hour CEU program would certainly cost substantially more.
  2. Fees must be collected for all those in attendance. Such fees may not be waived or subsidized by the Company.
  3. All monies received by the applicable training program will be collected by the Training and Development department for use in advancing the Company’s training programs.

Failure to comply with this policy represents a violation of the Company’s compliance program. Any questions regarding this policy should be directed to the Chief Compliance Officer or designee.