Fee-for-service arrangements with HCPs (such as agreements to serve as speakers, advisory board members, training consultants, etc.) should have legitimate, documented business needs and never be made with the intent to provide compensation or remuneration in exchange for business—actual or expected.

• Services should be documented in a detailed agreement that specifies the complete compensation package. (See your Johnson & Johnson Company contact for examples.)
• Compensation should be at fair market value for the services provided.
• Services performed must be documented before payment is made.
• Invoices should be detailed enough to enable proper recordkeeping and auditing.
• Associated travel, lodging, and meal expenses should be reasonable, not excessive, and not include side trips, unrelated trip extensions, or individuals who are not providing services to Johnson & Johnson.