ASP Educational Grants and Goodwill

Criteria for Grant Denials

Educational grant requests are reviewed through a rigorous review process. Processes have been designed and implemented so that no single individual may authorize educational grant support alone. In accordance with government guidance, it is inappropriate for individuals responsible for sales and marketing to be involved in educational grant-making decisions. Grant reviewers typically include personnel from Medical Affairs, Medical Education, Regulatory Affairs, Health Care Compliance, and/or Legal departments, as necessary.

Numerous educational grant requests can be received by ASP each year. Unfortunately, not all educational grants that are submitted for consideration can be funded.

ASP abides by rules developed by several regulatory and policy-making organizations. These rules provide guidance on several parameters. For example:

• Grants should not take into account the volume or value of purchases made by, or anticipated from, a potential grant recipient;
• Accredited educational activities should be independent and without influence from commercial supporters;
• Educational grants may only be provided to recognized institutions, organizations, or societies; no funding may be provided by industry directly to an individual or medical practice;
• Presentations must give a balanced view of therapeutic options and not a specific proprietary business interest (product) of a commercial sponsor; and
• Any gift items provided to participating practitioners must provide educational value to the patient or healthcare professional.

ASP uses established policies to evaluate each submission on its own merits. Funds are not provided as "unrestricted educational grants," which implies that recipients may use the financial support for a purpose other than what was originally intended. Although ASP only provides restricted educational grants, it is assumed that program content is developed in an independent manner by the requestor. It is expected that a provider should develop accredited medical education activities without interference, direct or nuanced, from a commercial supporter.

To ensure that the purpose of the educational activity is clearly understood, all grant requests include several key components to be provided within the grant application when submitting a grant request to our organization.

Each grant request submission is evaluated on four common components:

• The needs assessment documenting why the activity is necessary and how the proposed activity will address the educational need or gap
• A proposed or final agenda and/or brochure
• A detailed budget outlining how the funds will be utilized
• A statement of accreditation and/or tax exempt status

Unfortunately, educational grants may be denied for a variety of reasons. The primary criterion used by reviewers is that there must be a bona fide educational purpose that should result in improved patient care.

Examples of reasons for denial of educational grants may include:

• Vague or incomplete grant applications
• Requests that appear to promote a medical practice or office
• Support for educational activities that are outside the therapeutic scope of legitimate scientific or clinical interests of the manufacturer
• Funds to offset travel costs of attendees at an educational activity, other than a qualifying resident or fellow in training
• Grants to specifically promote an individual product
• Activities that include topics in a non-accredited environment that are designed to encourage unapproved uses of products
• Events that include a social activity or entertainment that overshadow the educational activity
• Requests that stipulate support is required in order to maintain access to health facilities, maintaining existing business relationships, or other quid pro quo
• All or parts of the proposed budget submitted by the requesting organization exceed fair market values (i.e., faculty honoraria, venue costs, or administrative fees)
• Limited funds available in ASP's educational budget
• Recent funding of similar educational activity

More information about reporting of grants and contributions can be found at www.jnj.com.