We maintain inventory management agreements (IMAs) with our U.S. pharmaceutical wholesalers, which account for nearly 100% of  our gross U.S. sales. Under the current terms of the IMAs, our wholesaler customers provide us with weekly information with respect  to months on hand product-level inventories and the amount of out-movement of products. The three largest wholesalers currently  account for approximately 90% of our gross U.S. sales. The inventory information received from our wholesalers, together with our  internal information, is used to estimate months on hand product level inventories at these wholesalers. We estimate months on hand  product inventory levels for our U.S. business’s wholesaler customers other than the three largest wholesalers by extrapolating from  the months on hand calculated for the three largest wholesalers. In contrast, our non-U.S. business has significantly more direct  customers, limited information on direct customer product level inventory and corresponding out-movement information and the  reliability of third-party demand information, where available, varies widely. Accordingly, we rely on a variety of methods to  estimate months on hand product level inventories for these business units.  Bristol-Myers Squibb  We believe the above-described procedures provide a reasonable basis to ensure compliance with the Consent.  None applicable.  The preparation of financial statements requires the use of estimates and assumptions that affect the reported amounts of assets and  liabilities and the reported amounts of revenue and expenses. Our critical accounting policies are those that significantly impact our  financial condition and results of operations and require the most difficult, subjective or complex judgments, often as a result of the  need to make estimates about the effect of matters that are inherently uncertain. Because of this uncertainty, actual results may vary  from these estimates. These accounting policies were discussed with the Audit Committee of the Board of Directors.  Recently Issued Accounting Standards  Critical Accounting Policies Revenue Recognition  Our accounting policy for revenue recognition has a substantial impact on reported results and relies on certain estimates. We  recognize revenue when persuasive evidence of an arrangement exists, the sales price is fixed and determinable, collectability is  reasonably assured and title and substantially all of the risks and rewards of ownership have transferred, which is generally at time of  shipment. Revenue is also reduced for gross-to-net sales adjustments discussed below, all of which involve significant estimates and  judgment after considering legal interpretations of applicable laws and regulations, historical experience, payer channel mix (e.g.  Medicare or Medicaid), current contract prices under applicable programs, unbilled claims and processing time lags and inventory  levels in the distribution channel. Estimates are assessed each period and adjusted as required to revised information or actual  experience. In addition, See “—Net Sales” above for further discussion and analysis of each significant category of gross-to-net sales  adjustments.  The following categories of gross-to-net sales adjustments involve significant estimates, judgments and information obtained from  external sources. See “—Net Sales” above for further discussion and analysis of each significant category of gross-to-net sales  adjustments.  Our U.S. business participates in programs with government entities, the most significant of which are the U.S. Department of  Defense and the U.S. Department of Veterans Affairs, and other parties, including covered entities under the 340B Drug Pricing  Program, whereby pricing on products is extended below wholesaler list price to participating entities. These entities purchase  products through wholesalers at the lower program price and the wholesalers then charge us the difference between their acquisition  cost and the lower program price. Accounts receivable is reduced for the estimated amount of un-processed charge-back claims  attributable to a sale (typically within a two to four week time lag).  In the U.S. and certain other countries, cash discounts are offered as an incentive for prompt payment, generally approximating 2% of  the sales price. Accounts receivable is reduced for the estimated amount of un-processed cash discounts (typically within a 1 month  time lag). Gross-to-Net Sales Adjustments  Charge-backs related to government programs  Cash discounts  22