WBMD » Topics » Government regulation and industry initiatives could adversely affect the volume of sponsored online CME programs implemented through our Web sites or require changes to how we offer CME

This excerpt taken from the WBMD 8-K filed Jul 2, 2009.
Government regulation and industry initiatives could adversely affect the volume of sponsored online CME programs implemented through our Web sites or require changes to how Medscape, LLC offers CME
 
CME activities may be subject to government oversight or regulation by Congress, the FDA, the Department of Health and Human Services, the federal agency responsible for interpreting certain federal laws relating to healthcare, and by state regulatory agencies. Medscape, LLC and/or the sponsors of the CME activities that Medscape, LLC accredits may be subject to enforcement actions if any of these CME activities are deemed improperly promotional, potentially leading to the termination of sponsorships.


11


 

During the past several years, educational activities, including CME, directed at physicians have been subject to increased governmental scrutiny to ensure that sponsors do not influence or control the content of the activities. For example, the U.S. Senate Finance Committee conducted an investigation of the sponsorship of CME activities, including an examination of the ACCME’s role in ensuring that CME activities are independent from the influence of their supporters. In response, pharmaceutical companies and medical device companies have developed and implemented internal controls and procedures that promote adherence to applicable regulations and requirements. In implementing these controls and procedures, supporters of CME may interpret the regulations and requirements differently and may implement varying procedures or requirements. These controls and procedures:
 
  •  may discourage pharmaceutical companies from providing grants for independent educational activities;
 
  •  may slow their internal approval for such grants;
 
  •  may reduce the volume of sponsored educational programs that Medscape, LLC produces to levels that are lower than in the past, thereby reducing revenue; and
 
  •  may require Medscape, LLC to make changes to how it offers or provides educational programs, including CME.
 
In addition, future changes to laws, regulations or accreditation standards, or to the internal compliance programs of supporters or potential supporters, may further discourage, significantly limit, or prohibit supporters or potential supporters from engaging in educational activities with Medscape, LLC, or may require Medscape, LLC to make further changes in the way it offers or provides educational activities.
 
 
 
 
This excerpt taken from the WBMD 10-Q filed May 11, 2009.
Government regulation and industry initiatives could adversely affect the volume of sponsored online CME programs implemented through our Web sites or require changes to how Medscape, LLC offers CME
 
CME activities may be subject to government oversight or regulation by Congress, the FDA, the Department of Health and Human Services, the federal agency responsible for interpreting certain federal laws relating to healthcare, and by state regulatory agencies. Medscape, LLC and/or the sponsors of the CME activities that Medscape, LLC accredits may be subject to enforcement actions if any of these CME activities are deemed improperly promotional, potentially leading to the termination of sponsorships.
 
During the past several years, educational activities, including CME, directed at physicians have been subject to increased governmental scrutiny to ensure that sponsors do not influence or control the content of the activities. For example, the U.S. Senate Finance Committee conducted an investigation of the sponsorship of CME activities, including an examination of the ACCME’s role in ensuring that CME activities are independent from the influence of their supporters. In response, pharmaceutical companies and medical device companies have developed and implemented internal controls and procedures that promote adherence to applicable regulations and requirements. In implementing these controls and procedures, supporters of CME


43


Table of Contents

may interpret the regulations and requirements differently and may implement varying procedures or requirements. These controls and procedures:
 
  •  may discourage pharmaceutical companies from providing grants for independent educational activities;
 
  •  may slow their internal approval for such grants;
 
  •  may reduce the volume of sponsored educational programs that Medscape, LLC produces to levels that are lower than in the past, thereby reducing revenue; and
 
  •  may require Medscape, LLC to make changes to how it offers or provides educational programs, including CME.
 
In addition, future changes to laws, regulations or accreditation standards, or to the internal compliance programs of supporters or potential supporters, may further discourage, significantly limit, or prohibit supporters or potential supporters from engaging in educational activities with Medscape, LLC, or may require Medscape, LLC to make further changes in the way it offers or provides educational activities.
 
 
These excerpts taken from the WBMD 10-K filed Feb 27, 2009.
Government regulation and industry initiatives could adversely affect the volume of sponsored online CME programs implemented through our Web sites or require changes to how Medscape, LLC offers CME
 
CME activities may be subject to government oversight or regulation by Congress, the FDA, the Department of Health and Human Services, the federal agency responsible for interpreting certain federal laws relating to healthcare, and by state regulatory agencies. Medscape, LLC and/or the sponsors of the CME activities that Medscape, LLC accredits may be subject to enforcement actions if any of these CME activities are deemed improperly promotional, potentially leading to the termination of sponsorships.
 
During the past several years, educational activities, including CME, directed at physicians have been subject to increased governmental scrutiny to ensure that sponsors do not influence or control the content of the activities. For example, the U.S. Senate Finance Committee conducted an investigation of the sponsorship of CME activities, including an examination of the ACCME’s role in ensuring that CME activities are independent from the influence of their supporters. In response, pharmaceutical companies and medical device companies have developed and implemented internal controls and procedures that promote adherence to applicable regulations and requirements. In implementing these controls and procedures, supporters of CME


37


Table of Contents

may interpret the regulations and requirements differently and may implement varying procedures or requirements. These controls and procedures:
 
  •  may discourage pharmaceutical companies from providing grants for independent educational activities;
 
  •  may slow their internal approval for such grants;
 
  •  may reduce the volume of sponsored educational programs that Medscape, LLC produces to levels that are lower than in the past, thereby reducing revenue; and
 
  •  may require Medscape, LLC to make changes to how it offers or provides educational programs, including CME.
 
In addition, future changes to laws, regulations or accreditation standards, or to the internal compliance programs of supporters or potential supporters, may further discourage, significantly limit, or prohibit supporters or potential supporters from engaging in educational activities with Medscape, LLC, or may require Medscape, LLC to make further changes in the way it offers or provides educational activities.
 
 
Government
regulation and industry initiatives could adversely affect the
volume of sponsored online CME programs implemented through our
Web sites or require changes to how Medscape, LLC offers
CME



 



CME activities may be subject to government oversight or
regulation by Congress, the FDA, the Department of Health and
Human Services, the federal agency responsible for interpreting
certain federal laws relating to healthcare, and by state
regulatory agencies. Medscape, LLC
and/or the
sponsors of the CME activities that Medscape, LLC accredits may
be subject to enforcement actions if any of these CME activities
are deemed improperly promotional, potentially leading to the
termination of sponsorships.


 



During the past several years, educational activities, including
CME, directed at physicians have been subject to increased
governmental scrutiny to ensure that sponsors do not influence
or control the content of the activities. For example, the
U.S. Senate Finance Committee conducted an investigation of
the sponsorship of CME activities, including an examination of
the ACCME’s role in ensuring that CME activities are
independent from the influence of their supporters. In response,
pharmaceutical companies and medical device companies have
developed and implemented internal controls and procedures that
promote adherence to applicable regulations and requirements. In
implementing these controls and procedures, supporters of CME





37





Table of Contents






may interpret the regulations and requirements differently and
may implement varying procedures or requirements. These controls
and procedures:


 














































  • 

may discourage pharmaceutical companies from providing grants
for independent educational activities;
 
  • 

may slow their internal approval for such grants;
 
  • 

may reduce the volume of sponsored educational programs that
Medscape, LLC produces to levels that are lower than in the
past, thereby reducing revenue; and
 
  • 

may require Medscape, LLC to make changes to how it offers or
provides educational programs, including CME.


 



In addition, future changes to laws, regulations or
accreditation standards, or to the internal compliance programs
of supporters or potential supporters, may further discourage,
significantly limit, or prohibit supporters or potential
supporters from engaging in educational activities with
Medscape, LLC, or may require Medscape, LLC to make further
changes in the way it offers or provides educational activities.


 




 




This excerpt taken from the WBMD 10-Q filed Nov 10, 2008.
Government regulation and industry initiatives could adversely affect the volume of sponsored online CME programs implemented through our Web sites or require changes to how Medscape offers CME
 
CME activities may be subject to government regulation by Congress, the FDA, the Department of Health and Human Services, the federal agency responsible for interpreting certain federal laws relating to healthcare, and by state regulatory agencies. Medscape and/or the sponsors of the CME activities that Medscape accredits may be subject to enforcement actions if any of these CME activities are deemed improperly promotional, potentially leading to the termination of sponsorships.
 
During the past several years, educational activities, including CME, directed at physicians have been subject to increased governmental scrutiny to ensure that sponsors do not influence or control the content of the activities. In response, pharmaceutical companies and medical device companies have developed and implemented internal controls and procedures that promote adherence to applicable regulations and requirements. In implementing these controls and procedures, Medscape’s various sponsors may interpret the regulations and requirements differently and may implement varying procedures or requirements. These controls and procedures:
 
  •  may discourage pharmaceutical companies from providing grants for independent educational activities;
 
  •  may slow their internal approval for such grants;
 
  •  may reduce the volume of sponsored educational programs that Medscape produces to levels that are lower than in the past, thereby reducing revenue; and
 
  •  may require Medscape to make changes to how it offers or provides educational programs, including CME.
 
In addition, future changes to laws and regulations, or to the internal compliance programs of supporters or supporters, may further discourage, significantly limit, or prohibit supporters or potential supporters from engaging in educational activities with Medscape, or may require Medscape to make further changes in the way it offers or provides educational programs.
 
This excerpt taken from the WBMD 10-Q filed Aug 11, 2008.
Government regulation and industry initiatives could adversely affect the volume of sponsored online CME programs implemented through our Web sites or require changes to how Medscape offers CME
 
CME activities may be subject to government regulation by Congress, the FDA, the OIG, HHS, the federal agency responsible for interpreting certain federal laws relating to healthcare, and by state regulatory agencies. Medscape and/or the sponsors of the CME activities that Medscape accredits may be subject to enforcement actions if any of these CME activities are deemed improperly promotional, potentially leading to the termination of sponsorships.
 
During the past several years, educational activities, including CME, directed at physicians have been subject to increased governmental scrutiny to ensure that sponsors do not influence or control the content of the activities. In response, pharmaceutical companies and medical device companies have developed and implemented internal controls and procedures that promote adherence to applicable regulations and requirements. In implementing these controls and procedures, Medscape’s various sponsors may interpret the regulations and requirements differently and may implement varying procedures or requirements. These controls and procedures:
 
  •  may discourage pharmaceutical companies from providing grants for independent educational activities;
 
  •  may slow their internal approval for such grants;
 
  •  may reduce the volume of sponsored educational programs that Medscape produces to levels that are lower than in the past, thereby reducing revenue; and
 
  •  may require Medscape to make changes to how it offers or provides educational programs, including CME.
 
In addition, future changes to laws and regulations, or to the internal compliance programs of supporters or supporters, may further discourage, significantly limit, or prohibit supporters or potential supporters from engaging in educational activities with Medscape, or may require Medscape to make further changes in the way it offers or provides educational programs.
 
This excerpt taken from the WBMD 10-Q filed May 12, 2008.
Government regulation and industry initiatives could adversely affect the volume of sponsored online CME programs implemented through our Web sites or require changes to how Medscape offers CME
 
CME activities may be subject to government regulation by Congress, the FDA, the OIG, HHS, the federal agency responsible for interpreting certain federal laws relating to healthcare, and by state regulatory agencies. Medscape and/or the sponsors of the CME activities that Medscape accredits may be subject to enforcement actions if any of these CME activities are deemed improperly promotional, potentially leading to the termination of sponsorships.
 
During the past several years, educational activities, including CME, directed at physicians have been subject to increased governmental scrutiny to ensure that sponsors do not influence or control the content of the activities. In response, pharmaceutical companies and medical device companies have developed and implemented internal controls and procedures that promote adherence to applicable regulations and requirements. In implementing these controls and procedures, Medscape’s various sponsors may interpret the regulations and requirements differently and may implement varying procedures or requirements. These controls and procedures:
 
  •  may discourage pharmaceutical companies from providing grants for independent educational activities;
 
  •  may slow their internal approval for such grants;
 
  •  may reduce the volume of sponsored educational programs that Medscape produces to levels that are lower than in the past, thereby reducing revenue; and
 
  •  may require Medscape to make changes to how it offers or provides educational programs, including CME.
 
In addition, future changes to laws and regulations, or to the internal compliance programs of supporters or supporters, may further discourage, significantly limit, or prohibit supporters or potential supporters from engaging in educational activities with Medscape, or may require Medscape to make further changes in the way it offers or provides educational programs.


49


Table of Contents

These excerpts taken from the WBMD 10-K filed Feb 29, 2008.
Government regulation and industry initiatives could adversely affect the volume of sponsored online CME programs implemented through our Web sites or require changes to how Medscape offers CME
 
CME activities may be subject to government regulation by Congress, the FDA, the OIG, HHS, the federal agency responsible for interpreting certain federal laws relating to healthcare, and by state regulatory agencies. Medscape and/or the sponsors of the CME activities that Medscape accredits may be subject to enforcement actions if any of these CME activities are deemed improperly promotional, potentially leading to the termination of sponsorships.
 
During the past several years, educational activities, including CME, directed at physicians have been subject to increased governmental scrutiny to ensure that sponsors do not influence or control the content of the activities. In response, pharmaceutical companies and medical device companies have developed and implemented internal controls and procedures that promote adherence to applicable regulations and requirements. In implementing these controls and procedures, Medscape’s various sponsors may interpret the regulations and requirements differently and may implement varying procedures or requirements. These controls and procedures:
 
  •  may discourage pharmaceutical companies from providing grants for independent educational activities;
 
  •  may slow their internal approval for such grants;
 
  •  may reduce the volume of sponsored educational programs that Medscape produces to levels that are lower than in the past, thereby reducing revenue; and
 
  •  may require Medscape to make changes to how it offers or provides educational programs, including CME.
 
In addition, future changes to laws and regulations, or to the internal compliance programs of supporters or supporters, may further discourage, significantly limit, or prohibit supporters or potential supporters from engaging in educational activities with Medscape, or may require Medscape to make further changes in the way it offers or provides educational programs.


40


Table of Contents

Government
regulation and industry initiatives could adversely affect the
volume of sponsored online CME programs implemented through our
Web sites or require changes to how Medscape offers
CME



 



CME activities may be subject to government regulation by
Congress, the FDA, the OIG, HHS, the federal agency responsible
for interpreting certain federal laws relating to healthcare,
and by state regulatory agencies. Medscape
and/or the
sponsors of the CME activities that Medscape accredits may be
subject to enforcement actions if any of these CME activities
are deemed improperly promotional, potentially leading to the
termination of sponsorships.


 



During the past several years, educational activities, including
CME, directed at physicians have been subject to increased
governmental scrutiny to ensure that sponsors do not influence
or control the content of the activities. In response,
pharmaceutical companies and medical device companies have
developed and implemented internal controls and procedures that
promote adherence to applicable regulations and requirements. In
implementing these controls and procedures, Medscape’s
various sponsors may interpret the regulations and requirements
differently and may implement varying procedures or
requirements. These controls and procedures:


 














































  • 

may discourage pharmaceutical companies from providing grants
for independent educational activities;
 
  • 

may slow their internal approval for such grants;
 
  • 

may reduce the volume of sponsored educational programs that
Medscape produces to levels that are lower than in the past,
thereby reducing revenue; and
 
  • 

may require Medscape to make changes to how it offers or
provides educational programs, including CME.


 



In addition, future changes to laws and regulations, or to the
internal compliance programs of supporters or supporters, may
further discourage, significantly limit, or prohibit supporters
or potential supporters from engaging in educational activities
with Medscape, or may require Medscape to make further changes
in the way it offers or provides educational programs.





40





Table of Contents







This excerpt taken from the WBMD 10-Q filed Nov 9, 2007.
Government regulation and industry initiatives could adversely affect the volume of sponsored online CME programs implemented through our Web sites or require changes to how we offer CME
 
CME activities may be subject to government regulation by the FDA, the OIG, or HHS, the federal agency responsible for interpreting certain federal laws relating to healthcare, and by state regulatory agencies. During the past several years, educational programs, including CME, directed toward physicians have been subject to increased scrutiny to ensure that sponsors do not influence or control the content of the program. In response to governmental and industry initiatives, pharmaceutical companies and medical device companies have been developing and implementing internal controls and procedures that promote adherence to applicable regulations and requirements. In implementing these controls and procedures, different clients may interpret the regulations and requirements differently and may implement procedures or requirements that vary from client to client. These controls and procedures:
 
  •  may discourage pharmaceutical companies from engaging in educational activities;
 
  •  may slow their internal approval for such programs;
 
  •  may reduce the volume of sponsored educational programs implemented through our Web sites to levels that are lower than in the past; and
 
  •  may require us to make changes to how we offer or provide educational programs, including CME.
 
In addition, future changes to existing regulations, or to the internal compliance programs of clients or potential clients, may further discourage or prohibit clients or potential clients from engaging in educational activities with us, or may require us to make further changes in the way we offer or provide educational programs.
 
This excerpt taken from the WBMD 10-Q filed Aug 9, 2007.
Government regulation and industry initiatives could adversely affect the volume of sponsored online CME programs implemented through our Web sites or require changes to how we offer CME
 
CME activities may be subject to government regulation by the FDA, the OIG, or HHS, the federal agency responsible for interpreting certain federal laws relating to healthcare, and by state regulatory agencies. During the past several years, educational programs, including CME, directed toward physicians have been subject to increased scrutiny to ensure that sponsors do not influence or control the content of the program. In response to governmental and industry initiatives, pharmaceutical companies and medical device companies have been developing and implementing internal controls and procedures that promote adherence to applicable regulations and requirements. In implementing these controls and procedures, different clients may interpret the regulations and requirements differently and may implement procedures or requirements that vary from client to client. These controls and procedures:
 
  •  may discourage pharmaceutical companies from engaging in educational activities;
 
  •  may slow their internal approval for such programs;
 
  •  may reduce the volume of sponsored educational programs implemented through our Web sites to levels that are lower than in the past; and
 
  •  may require us to make changes to how we offer or provide educational programs, including CME.


45


Table of Contents

 
In addition, future changes to existing regulations, or to the internal compliance programs of clients or potential clients, may further discourage or prohibit clients or potential clients from engaging in educational activities with us, or may require us to make further changes in the way we offer or provide educational programs.
 
This excerpt taken from the WBMD 10-Q filed May 10, 2007.
Government regulation and industry initiatives could adversely affect the volume of sponsored online CME programs implemented through our Web sites or require changes to how we offer CME
 
CME activities may be subject to government regulation by the FDA, the OIG, or HHS, the federal agency responsible for interpreting certain federal laws relating to healthcare, and by state regulatory agencies. During the past several years, educational programs, including CME, directed toward physicians have been subject to increased scrutiny to ensure that sponsors do not influence or control the content of the program. In response to governmental and industry initiatives, pharmaceutical companies and medical device companies have been developing and implementing internal controls and procedures that promote adherence to applicable regulations and requirements. In implementing these controls and procedures, different clients may interpret the regulations and requirements differently and may implement procedures or requirements that vary from client to client. These controls and procedures:
 
  •  may discourage pharmaceutical companies from engaging in educational activities;
 
  •  may slow their internal approval for such programs;
 
  •  may reduce the volume of sponsored educational programs implemented through our Web sites to levels that are lower than in the past; and
 
  •  may require us to make changes to how we offer or provide educational programs, including CME.
 
In addition, future changes to existing regulations or to the internal compliance programs of clients or potential clients, may further discourage or prohibit clients or potential clients from engaging in educational activities with us, or may require us to make further changes in the way we offer or provide educational programs.
 
This excerpt taken from the WBMD 10-Q filed May 10, 2007.
Government regulation and industry initiatives could adversely affect the volume of sponsored online CME programs implemented through our Web sites or require changes to how we offer CME
 
CME activities may be subject to government regulation by the FDA, the OIG, or HHS, the federal agency responsible for interpreting certain federal laws relating to healthcare, and by state regulatory agencies. During the past several years, educational programs, including CME, directed toward physicians have been subject to increased scrutiny to ensure that sponsors do not influence or control the content of the program. In response to governmental and industry initiatives, pharmaceutical companies and medical device companies have been developing and implementing internal controls and procedures that promote adherence to applicable regulations and requirements. In implementing these controls and procedures, different clients may interpret the regulations and requirements differently and may implement procedures or requirements that vary from client to client. These controls and procedures:
 
  •  may discourage pharmaceutical companies from engaging in educational activities;
 
  •  may slow their internal approval for such programs;
 
  •  may reduce the volume of sponsored educational programs implemented through our Web sites to levels that are lower than in the past; and
 
  •  may require us to make changes to how we offer or provide educational programs, including CME.
 
In addition, future changes to existing regulations or to the internal compliance programs of clients or potential clients, may further discourage or prohibit clients or potential clients from engaging in educational activities with us, or may require us to make further changes in the way we offer or provide educational programs.
 
This excerpt taken from the WBMD 10-Q filed May 10, 2007.
Government regulation and industry initiatives could adversely affect the volume of sponsored online CME programs implemented through our Web sites or require changes to how we offer CME
 
CME activities may be subject to government regulation by the FDA, the OIG, or HHS, the federal agency responsible for interpreting certain federal laws relating to healthcare, and by state regulatory agencies. During the past several years, educational programs, including CME, directed toward physicians have been subject to increased scrutiny to ensure that sponsors do not influence or control the content of the program. In response to governmental and industry initiatives, pharmaceutical companies and medical device companies have been developing and implementing internal controls and procedures that promote adherence to applicable regulations and requirements. In implementing these controls and procedures, different clients may interpret the regulations and requirements differently and may implement procedures or requirements that vary from client to client. These controls and procedures:
 
  •  may discourage pharmaceutical companies from engaging in educational activities;
 
  •  may slow their internal approval for such programs;
 
  •  may reduce the volume of sponsored educational programs implemented through our Web sites to levels that are lower than in the past; and
 
  •  may require us to make changes to how we offer or provide educational programs, including CME.
 
In addition, future changes to existing regulations or to the internal compliance programs of clients or potential clients, may further discourage or prohibit clients or potential clients from engaging in educational activities with us, or may require us to make further changes in the way we offer or provide educational programs.


44


Table of Contents

 
This excerpt taken from the WBMD 10-K filed Mar 2, 2007.
Government regulation and industry initiatives could adversely affect the volume of sponsored online CME programs implemented through our Web sites or require changes to how we offer CME
 
CME activities may be subject to government regulation by the FDA, the OIG, or HHS, the federal agency responsible for interpreting certain federal laws relating to healthcare, and by state regulatory agencies. During the past several years, educational programs, including CME, directed toward physicians have been subject to increased scrutiny to ensure that sponsors do not influence or control the content of the program. In response to governmental and industry initiatives, pharmaceutical companies and medical device companies have been developing and implementing internal controls and procedures that promote adherence to applicable regulations and requirements. In implementing these controls and procedures, different clients may interpret the regulations and requirements differently and may implement procedures or requirements that vary from client to client. These controls and procedures:
 
  •  may discourage pharmaceutical companies from engaging in educational activities;
 
  •  may slow their internal approval for such programs;
 
  •  may reduce the volume of sponsored educational programs implemented through our Web sites to levels that are lower than in the past; and
 
  •  may require us to make changes to how we offer or provide educational programs, including CME.
 
In addition, future changes to existing regulations or to the internal compliance programs of clients or potential clients, may further discourage or prohibit clients or potential clients from engaging in educational activities with us, or may require us to make further changes in the way we offer or provide educational programs.
 
This excerpt taken from the WBMD 10-Q filed Nov 13, 2006.
Government regulation and industry initiatives could adversely affect the volume of sponsored online CME programs implemented through our Web sites or require changes to how we offer CME
 
CME activities may be subject to government regulation by the FDA, the OIG, or HHS, the federal agency responsible for interpreting certain federal laws relating to healthcare, and by state regulatory agencies. During the past several years, educational programs, including CME, directed toward physicians have been subject to increased scrutiny to ensure that sponsors do not influence or control the content of the program. In response to governmental and industry initiatives, pharmaceutical companies and medical device companies have been developing and implementing internal controls and procedures that promote adherence to applicable regulations and requirements. In implementing these controls and procedures, different clients may interpret the regulations and requirements differently and may implement procedures or requirements that vary from client to client. These controls and procedures:
 
  •  may discourage pharmaceutical companies from engaging in educational activities;
 
  •  may slow their internal approval for such programs;
 
  •  may reduce the volume of sponsored educational programs implemented through our Web sites to levels that are lower than in the past; and
 
  •  may require us to make changes to how we offer or provide educational programs, including CME.
 
In addition, future changes to existing regulations or to the internal compliance programs of clients or potential clients, may further discourage or prohibit clients or potential clients from engaging in educational activities with us, or may require us to make further changes in the way we offer or provide educational programs.
 
This excerpt taken from the WBMD 10-Q filed Aug 9, 2006.
Government regulation and industry initiatives could adversely affect the volume of sponsored online CME programs implemented through our Web sites or require changes to how we offer CME
 
CME activities may be subject to government regulation by the FDA, the OIG, or HHS, the federal agency responsible for interpreting certain federal laws relating to healthcare, and by state regulatory agencies. During the past several years, educational programs, including CME, directed toward physicians have been subject to increased scrutiny to ensure that sponsors do not influence or control the content of the program. In response to governmental and industry initiatives, pharmaceutical companies and medical device companies have been developing and implementing internal controls and procedures that promote adherence to applicable regulations and requirements. In implementing these controls and procedures, different clients may interpret the regulations and requirements differently and may implement procedures or requirements that vary from client to client. These controls and procedures:
 
  •  may discourage pharmaceutical companies from engaging in educational activities;
 
  •  may slow their internal approval for such programs;
 
  •  may reduce the volume of sponsored educational programs implemented through our Web sites to levels that are lower than in the past; and
 
  •  may require us to make changes to how we offer or provide educational programs, including CME.
 
In addition, future changes to existing regulations or to the internal compliance programs of clients or potential clients, may further discourage or prohibit clients or potential clients from engaging in educational activities with us, or may require us to make further changes in the way we offer or provide educational programs.
 
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