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White Guide and Orange Guide Formatting Project - Pfizer

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<strong>Orange</strong> <strong>Guide</strong> – Chapter 7: P&T Committee Interactions<br />

determining the appropriate content of the presentation (<strong>and</strong> the identity of the <strong>Pfizer</strong> colleague<br />

presenting) turns on who requested the formulary presentation—<strong>Pfizer</strong> or the P&T Committee.<br />

If <strong>Pfizer</strong> Requested the Opportunity to Present Information<br />

When <strong>Pfizer</strong> asks for the opportunity to present information, the presentation is promotional <strong>and</strong> the<br />

FDA rules surrounding product promotion apply. Accordingly, any colleague (including a Medical<br />

Colleague) that presents information in this situation must abide by the four Core Compliance<br />

Principles:<br />

Use only RC-approved materials <strong>and</strong> selling statements;<br />

Stay on-label <strong>and</strong> discuss only approved products <strong>and</strong> indications;<br />

Provide an accurate <strong>and</strong> balanced presentation; <strong>and</strong><br />

Never engage in actual or perceived quid pro quo.<br />

Each <strong>Pfizer</strong> product team is responsible for creating <strong>and</strong> maintaining a slide deck that is appropriate for<br />

use during formulary presentations. Only these <strong>and</strong> other RC-approved materials can be used when<br />

<strong>Pfizer</strong> has requested the opportunity to present information. If you would like to add slides to the slide<br />

deck, the slides must be approved by the appropriate <strong>Pfizer</strong> Review Committee before use. When<br />

proactively providing product information, colleagues must never include information about off-label<br />

uses, including efficacy or safety information that conflicts with the approved labeling. Colleagues<br />

must never include new clinical data that has not yet been approved for product promotion in the<br />

presentation materials. If a P&T Committee makes a specific unsolicited request for off-label<br />

information during the presentation, only Medical Colleagues (or a Headquarters approved physician<br />

consultant) may respond to the request in accordance with the guidelines set out for them (i.e., the<br />

Medical Colleague must acknowledge that the information is off-label; provide a brief answer which is<br />

truthful, not misleading, based on substantial scientific evidence <strong>and</strong> non-promotional in tone; <strong>and</strong><br />

then continue with the original presentation). Non-medical Colleagues may remain in the meeting<br />

during this time, but if a more extensive answer or discussion is needed to respond to the customer’s<br />

request, the Medical Colleague should speak to the customer after the meeting without the presence of<br />

Non-Medical Colleagues.<br />

131<br />

Rev. 09/12<br />

Page 9 of 11

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