White Guide and Orange Guide Formatting Project - Pfizer

Orange Guide – Chapter 7: P&T Committee Interactions
Taking a P&T Committee member out to a meal that is extravagant or otherwise not in
compliance with the PhRMA Code;
Providing any payment (such as an exhibit/display fee or speaker fee) to a P&T Committee
member or their institution if the payment is even partially motivated by a desire to
influence an upcoming formulary decision;
Providing any unapproved item to a P&T Committee member; and
Linking financial support from Pfizer, either directly or indirectly, with influence over that
P&T Committee member's exercise of judgment in serving on their P&T Committee.
Discussion of Extraneous Financial Transactions
To avoid violating the anti-kickback laws, Pfizer strictly prohibits linking financial transactions (other
than disclosed rebate or discount arrangements) to P&T Committee decisions. Outside of certain
limited exceptions, anti-kickback laws prohibit manufacturers from providing anything of value in
order to influence formulary decisions. Any separate financial arrangements could also affect Pfizer's
government pricing obligations under federal and state law.
Thus, when discussing formulary placement or Pfizer products with a P&T Committee member, you
must never include offers of any sort to provide quality or product support programs, educational or
research grants, charitable contributions, exhibit or display payments, or other arrangements
(including speaking engagements) in exchange for formulary positioning. Consistent with the
PhRMA Code, Pfizer requires any HCP who is a member of a P&T Committee and also speaks or
consults for Pfizer to disclose to their P&T Committee the existence and nature of their relationship
with Pfizer.
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Rev. 09/12
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