At Forest, compliance with the laws and regulations that govern our industry is a responsibility we focus on every day as we carry out our mission to improve patients' health and quality of life. Our Comprehensive Compliance Program is designed not only to fulfill these requirements, but to ensure that our business activities are conducted consistent with the highest standards of ethics and professionalism, and in a manner that benefits the healthcare community and, most importantly, patients.
Adherence to the PhRMA Code and OIG Guidance
As required by certain state law requirements, Forest posts select examples of applicable guidelines and policies on this website. These documents provide an overview of Forest's Comprehensive Compliance Program.
Forest Laboratories, Inc PhRMA & OIG Adherence
In accordance with Section 119402 of the California Health & Safety Code, the following documents contain information about:
These documents are free to be referenced and downloaded via this website. (NOTE: To obtain a hard copy version of information referenced in the Comprehensive Compliance Program via postal mail, you may be required to provide specific information.)
Consistent with commitments Forest has made under a Corporate Integrity Agreement entered into with the U.S. Department of Health and Human Services, Forest publicly discloses information about its funding for Industry Support and about payments and transfers of value to physicians and certain related entities.
Forest is committed to supporting healthcare organizations and initiatives that provide valuable education or services to the healthcare community, patients, and caregivers. Forest provides support for medical education programs dedicated in content and emphasis to the advancement of objective scientific and educational discourse, in order to further healthcare provider and patient education; programs that improve patient access to care; and disease awareness programs. Forest also provides general support consistent with Forest’s corporate mission and public health objectives.
Information about Forest’s Industry Support program (including grants, sponsorships, and general contributions), and Forest’s Transparency Reports, can be found on Forest’s Industry Support website (www.frxis.com).
Relationships with Healthcare Professionals
Forest believes that appropriate interactions with healthcare professionals are critical to advancing the development of new medicines and improving patients’ health and quality of life. In our interactions with healthcare professionals, we stress the communication of accurate scientific and educational information about our products, so as to enable healthcare professionals to make the best possible treatment decisions for their patients.
In the course of our interactions with healthcare professionals, we sometimes provide such professionals with payments or other items of value. These may include payments for services provided by such professionals, such as consulting or speaking activities, and associated reimbursement for reasonable travel expenses; modest meals or snacks incidental to presentations about Forest products or incurred while providing services for Forest; modest educational items; or support for independent scientific research.
Forest works hard to ensure that all aspects of our interactions with healthcare professionals, including the provision of payments or other transfers of value, are conducted consistent with the highest legal and ethical standards, and solely for bona fide business and educational purposes. Consistent with this objective, and in accordance with our commitments under our Corporate Integrity Agreement, we provide on this website a Disclosure Report that contains information about our financial relationships with physicians. Forest’s Disclosure Report includes information about U.S.-based physicians and related entities who have received payments or transfers of value from Forest, such as those described above. Forest’s Clinical Research Disclosure Report includes information about payments made to U.S. research institutions and entities, hospitals, and physicians in connection with Forest-sponsored clinical research.
Please click the links below to view Forest's Disclosure Reports.
- Please take the time to review and understand the definitions and methodology used in preparing our Disclosure Reports.
- Forest has strived to create accurate reports by ensuring that our employees and vendors collect all relevant data and attribute payments accurately and consistently. Please note that due to occasional delays in reconciliation for certain indirect payments, some payments or transfers of value may not be included until a later reporting period, and some payments or transfers of value may be reclassified upon receipt of additional information. We will periodically update our Disclosure Reports as necessary. If you have a specific inquiry about a particular posted payment, please contact DisclosureReportInquiry@frx.com.
- What are Forest's Disclosure Reports?
The Disclosure Report contains a listing of U.S.-based physicians and related entities who received certain types of payments or transfers of value directly or indirectly from Forest during a defined time period. The Clinical Research Disclosure Report contains a listing of U.S.-based research institutions and entities, hospitals, and physicians who received payments in connection with Forest-sponsored clinical research during a defined period.
- What Information is Included in the Disclosure Report?
The Disclosure Report contains information about the name of the physician who received a relevant payment or transfer of value; the name of a related entity, if applicable; the amount of the payment or transfer of value reported; the city/state associated with the physician’s license on record; and the purpose of the payment or transfer of value.
- What is a Related Entity?
Pursuant to Forest's Corporate Integrity Agreement, payments to related entities (defined as an entity by or in which a physician is employed, has tenure, or has an ownership interest) are reported when the payment is made to the entity on behalf of, at the request of, for the benefit or use of, or under the name of a physician for whom Forest would otherwise report a payment if made directly to the physician.
- What types of payments and transfers of value are included in the report?
The Disclosure Report includes payments or transfers of value greater than or equal to $10.00, or where the aggregate amount paid to an individual physician is greater than $100.00 per year, all payments or transfers of value to an individual physician.
The following types of payments and transfers of value may be included in the Disclosure Report:
Fees paid to physicians in compensation for providing bona fide consulting services to Forest. Forest’s consulting engagements with healthcare professionals are critical to advancing scientific knowledge and research, and to developing more effective therapies. Consulting services may be provided on an individual basis or through participation in advisory boards or roundtables. Consultants enter into a contracted consulting engagement and are paid a fair market value rate.
Fees paid to a physician in compensation for services rendered in connection with presentations at Forest-sponsored peer-to-peer educational programs. Forest believes educational exchanges among peers are critical in disseminating accurate information about our products and improving patient care. Physicians who perform speaking services are compensated at a fair market value rate. Peer-to-peer educational programs sponsored by Forest are promotional in nature and are governed by FDA laws and regulations.
Business Travel Expenses:
Costs incurred and expenses paid in connection with business travel by physicians serving as consultants or speakers for Forest, including transportation and lodging. Pursuant to Forest policy, any travel expenses incurred by a consultant or speaker must be reasonable in nature and properly documented.
Items designed primarily for the education of patients or healthcare professionals that comply with the Pharmaceutical Research and Manufacturers of America Code on Interactions with Healthcare Professionals (the "PhRMA Code"). Such items are not of substantial value and are not intended to have value to healthcare professionals outside of their professional responsibilities.
The estimated value of food or snacks provided to a physician in connection with an educational exchange or presentation relating to Forest products. Forest occasionally provides modest meals and snacks during educational interactions relating to its products in recognition of the fact that physicians have busy schedules that require them to balance patient care and other responsibilities. Pursuant to Forest policy, such food items are provided consistent with the principles in the PhRMA Code. Estimated dollar values for meals are typically calculated by dividing the overall cost of the meal by the number of attendees or participants. The per-capita amount included in the Disclosure Report may or may not be representative of an individual physician’s actual consumption.
This category also captures meal costs and expense reimbursements for food consumed by healthcare professionals while performing their duties as a consultant or speaker for Forest. As a result, the reported amount for a particular physician may in some instances reflect both food consumed as an attendee at a Forest-sponsored educational program and food consumed by a consultant or speaker in the course of performing services for Forest.
Funding that supports a physician's independent research intended to expand scientific knowledge relating to an FDA-approved drug or Forest-initiated clinical research. Independent research proposals are unsolicited by Forest and derived from the academic research interests or clinical experience of independent investigators.
- What time periods are covered in the Disclosure Report?
Forest posts quarterly Disclosure Reports for relevant payments and transfers of value within 60 days following the end of each calendar quarter and an annual Disclosure Report within 60 days following the end of a calendar year.
- What Information is Included in the Clinical Research Disclosure Report?
The Clinical Research Disclosure Report lists research institutions and entities, hospitals, and physicians who received payments in connection with Forest-sponsored clinical research; the name of the associated principal investigator, if applicable; the amount of the payment; and the city/state associated with the payee’s address. For each payment included on the Clinical Research Report, Forest has included the name of the Principal Investigator (PI) associated with the research. Please note, the inclusion of a PI's name in connection with a particular payment does not mean that the PI necessarily received any or all of the payment or transfer of value. In many cases, some or all of the payment may have been used by the payee to support payments to other healthcare professionals working on the research.
- What time periods are covered in the Clinical Research Disclosure Report?
Forest posts quarterly Clinical Research Disclosure Reports for relevant payments and transfers of value within 60 days following the end of each calendar quarter and an annual Disclosure Report within 60 days following the end of a calendar year.