Where it is permissible to provide meals, travel, or lodging to an HCP (such as in the context of a fee-for-service arrangement), the following requirements apply:
- Reasonable, documented expenses for travel, lodging, and meals must be reimbursed in accordance with the Johnson & Johnson Travel and Entertainment Policy and applicable local policies.
- The location and venue of any meeting with an HCP must be suitable for and conducive to the exchange of business or scientific information.
- Meals and refreshments must be modest in value and supplemental, in time and focus, to the business part of the meeting.
- Entertainment or recreation may not be provided to HCPs.
- Payments should be tied to milestones and/or deliverables; there should be no advance lump-sum payments.
- There are no exceptions for interactions involving one-day events and/or small monetary amounts.