White Guide and Orange Guide Formatting Project - Pfizer

Orange Guide – Chapter 5: Interactions with Health Systems and Medical Groups
Chapter 5: INTERACTIONS WITH HEALTH
SYSTEMS AND MEDICAL GROUPS
Introduction
Pfizer’s customers are increasingly being organized into large healthcare delivery organizations such as
large medical groups and integrated delivery networks or systems (collectively, “Health Systems”). It is
important to understand that working with these customers can present unique legal risks if not done in
the appropriate manner.
If a colleague gives – or could be perceived as giving – a Health System customer something of
value as an inducement for prescribing of or recommending a product, that potentially
implicates state and federal anti-kickback laws.
Further, if that offering of value inadvertently affects or could appear to affect the prices of
Pfizer products that a customer is purchasing, that could cause Pfizer not to report accurately
the price of its products in submissions it makes to the government under the Medicaid Drug
Rebate Program and other health care programs.
In addition, if a colleague communicates with a Health System around a product, outcomes, or
therapeutic area in a manner that could make express or implied comparative claims that are
not consistent with Pfizer approved messaging, that could expose Pfizer to liability for
inappropriate messaging around our products.
This Chapter summarizes key Pfizer policies regarding interactions by commercial field-based
colleagues with Health Systems. Non-compliance with these policies puts the Company at risk and
can subject colleagues to disciplinary action up to and including termination.
If the application of any policy is unclear to you, discuss the issue with your manager or your team
attorney.
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