White Guide and Orange Guide Formatting Project - Pfizer

Discussing Payer Rebates
Medical Activities
Orange Guide – Chapter 5: Interactions with Health Systems and Medical Groups
Q. One of my customers is a mid-size medical group that manages its own
formulary and is a custom client under payer customer. Pfizer’s drug does not
have favorable access at the medical group customer. I would like to engage in
discussions with this customer about the clinical benefits of the drug and the
potential benefits to the practice’s patients. Can I discuss rebates received by the
affiliated payer customer under contract with Pfizer? Can I provide tools or
engage in adherence arrangements in conjunction with or in exchange for
formulary access?
A. No. Pfizer colleagues should not discuss rebates received by the affiliated payer
customer or any other customer with a medical group as that will violate
contractual confidentiality obligations Pfizer has with those customers. Even
though the medical group is a client of the payer customer, Pfizer’s contract is
with the payer and discussions related to the terms of those contracts must
remain confidential. Additionally, Pfizer colleagues should not provide tools or
engage in adherence arrangements in conjunction with or in exchange for
formulary access. Comingling other arrangements with formulary discussions
elevates risk under the anti-kickback statute and raises the risk that separate,
non-rebate arrangements might need to be considered for purposes of price
reporting.
Customer medical requests should be addressed by the appropriate Pfizer Medical Colleague. A
commercial colleague, for example, should not perform either directly or through a vendor a
pharmacoeconomic, health outcome, or any customer generated data analysis.
While a commercial colleague, along with a medical colleague, may at a high level discuss clinical
research needs and opportunities with a customer as part of a needs assessment, the Medical Colleague
should take the lead on any potential work that comes out of such assessment. In some instances, the
commercial colleague may continue to participate in joint meetings with medical, but in other
circumstances there will need to be a clear separation of activities, thus requiring the commercial
colleague to not be involved at all. Colleagues should follow the Orange Guide provisions which
describe how you should appropriately involve MOS and RMRS Colleagues, as noted in Orange Guide
Chapter 2: Detailing to HCPs, under the headings “Interacting with MOS Colleagues” and “Interacting
111
Rev. 09/12
Page 16 of 18