Lantheus is committed to full transparency under the US Physician Payment Sunshine Act and US State-level disclosure laws.
Over the past several years, there have been an increased number of Federal and State laws that require transparency into the relationships between pharmaceutical and medical device companies with healthcare providers. These laws impose various combinations of tracking and reporting of payments, transfers of value, compliance with PhRMA Code, and compliance with our own internal policies and procedures. Lantheus complies with all applicable laws, including the federal Sunshine Act and state regulations in Massachusetts, California, Minnesota, Nevada, District of Columbia, Vermont, West Virginia and Connecticut.
The Sunshine Act requires Applicable Manufacturers and Applicable Group Purchasing Organizations (GPOs) to report to the Centers of Medicare & Medicaid Services (“CMS”) any “direct” or “indirect” payment or other transfer of value provided to a Covered Recipient or any payment provided to a third party on behalf of a covered recipient during a calendar year. Covered recipients under the Sunshine act are either US Licensed Physicians (doctors of medicine and osteopathy, dentists, podiatrists, optometrists, and chiropractors [residents are not included]) or Teaching Hospitals (CMS will publish a list of teaching hospitals 90 days prior to the start of data collection each year).
The intent is to provide transparency into the financial relationships between manufacturers, physicians and teaching hospitals to enable patients to make informed decisions regarding treatment and to prevent inappropriate influences on research, education and clinical decision-making.
Payments and “transfers of value” are defined as cash or cash equivalent, in-kind items or services, stock, stock options, ownership interest, dividend, profit or other return on investment. In addition, manufacturers must specify the nature of the payment that is made either directly or indirectly to a physician. Examples of such are consulting fees, honoraria, gifts, entertainment, food and beverage, travel and lodging, education, etc.
How to Report a Compliance Concern
Lantheus is committed to conducting its business on a daily basis consistent with the highest standards of ethical conduct, fairness, integrity and respect for the law and its corporate values. Lantheus maintains a third-party confidential reporting system for the receipt, retention and treatment of complaints regarding Lantheus’ accounting, internal accounting controls, auditing matters, policy, safety, human resource matters, violation (or possible violation) of laws and and other compliance concerns. You may report a problem or concern by making a report via the Company’s web-based reporting tool at www.lantheus.ethicspoint.com or by calling the Company’s Compliance Concern Hotline at 1-877-472-6272 for calls placed within the United States, or 1-503-747-1848 for calls placed outside the United States. Calls and submission are anonymous (unless the caller self-identifies) and will be directed to the appropriate individuals at Lantheus.
California – Annual Declaration of Compliance
California Health and Safety Code § 119402
Lantheus Medical Imaging, Inc. declares that, to the best of our knowledge and based upon our good faith understanding of the statutory requirements as of the date of this declaration, our Compliance Program complies with the requirements of California Health and Safety Code § 119402 insofar as they apply to pharmaceutical and/or certain medical device companies.
For purposes of complying with the California Compliance Law, Lantheus Medical Imaging has established a maximum annual aggregate dollar limit of $1,500 for appropriate covered items provided to California medical or healthcare professionals. Examples of covered items may include educational items, such as medical textbooks, modest meals provided in connection with a discussion regarding a company product or disease, and other items or activities permitted under the PhRMA Code. This annual limit represents a maximum amount, not an average, and may be revised in the future.
Lantheus is committed to the highest standards of ethical conduct. Lantheus has implemented a third-party confidential reporting system for the receipt, retention and treatment of complaints regarding Lantheus’ accounting, internal accounting controls, auditing matters and other compliance concerns. You may report a problem or concern regarding accounting, internal accounting controls, auditing matters or other compliance concerns by calling the Company’s Compliance Concern Hotline at 1-877-472-6272 for calls placed within the United States, or 1-678-999-4548 for calls placed outside the United States. If you wish to remain anonymous, please do not provide any personal or identifying information.