White Guide and Orange Guide Formatting Project - Pfizer

Orange Guide – Chapter 5: Interactions with Health Systems and Medical Groups
Avoid Combining Types of Transactions
As the lines between customer types (payers, prescribers, purchasers, etc.) have begun to blur, it is
important to ensure separateness among Pfizer’s functions and certain activities to avoid the actual or
perceived commingling of transactions which could raise anti-kickback and pricing concerns. For
example, when engaging with a customer, particular initiatives should be pursued in and of themselves,
and should not be predicated on other programs or additional performance of any kind.
When different transactions are commingled – such as if an MMWeb tool is offered to secure formulary
placement - there can be a risk that the value to the customer of that separate, non-rebate related
arrangement might need to be considered and included as a discount to the customer for purposes of
price reporting under the Medicaid Drug Rebate Statute for a drug. Therefore, avoid combining certain
types of transactions to avoid implicating pricing concerns. For example:
Do not attempt to leverage any additional (e.g., non-formulary) arrangements in order to
secure preferential formulary status.
Do not discuss grants, service agreements, CGC tools and resources, or other items of value in
connection with formulary discussions.
Do not link or reference the terms of Pfizer's commercial rebate agreement when negotiating
a collaboration.
Do not discuss the formulary status of a Pfizer product or ask for increased product utilization
as part of a collaboration.
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