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interact directly with healthcare professionals (hcps), healthcare institutions (hcis), consumers or independent third party patient assistance programs; or (ii) perform activities, provide services, or create materials relating to the covered functions and those activities, services, or materials are not
reviewed or supervised by a lundbeck employee who is a covered person prior to execution or dissemination. notwithstanding the above, the term "covered persons" does not include part time or per diem employees, contractors, subcontractors, agents, and other persons who are not reasonably expected to...
https://www.oig.hhs.gov/fraud/cia/agreements/Lundbeck_LLC_04032019.pdf