White Guide and Orange Guide Formatting Project - Pfizer

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Mentorships and Preceptorships Orange Guide – Chapter 8: Privacy: Protecting Personal Information A mentorship allows colleagues to observe or “shadow” an HCP engaged in his or her daily office or institutional practice. Payment to an HCP for serving as a mentor is prohibited. A preceptorship, on the other hand, is a training presentation by an HCP to a team or group of colleagues about a particular therapeutic area or the clinical use of one or more Pfizer products in professional practice. The need for mentorships and preceptorships is limited; therefore, you should conduct these events infrequently and only when there is a documented need. These events may impact patient privacy if colleagues are permitted to observe treatment or consultation sessions with a patient, or if colleagues discuss an individual’s treatment with a patient’s HCP. When setting up a mentorship or preceptorship, colleagues must remind physicians serving as mentors or preceptors that they have a legal obligation to obtain their patient’s written authorization before colleagues may be allowed to observe any consultation, examination, or treatment. Pfizer has created a Patient Authorization template, available at http://pfieldnet.pfizer.com/Compliance/Documents/ called “Mentorship Guidelines (2)(mv)” to offer HCPs for use in obtaining a patient’s permission. The signed authorization form should be maintained as part of the patient’s record by the physician, and a copy should be given to the patient. There is no need or reason for you to have a copy of the form, so you should not collect or retain a signed copy of the form. Because patient privacy issues are often implicated when Pfizer employees are permitted to observe treatment or consultation sessions with patients and HCPs, colleagues must identify themselves as Pfizer employees so that the patient is fully aware of and understands the colleague’s role. For additional rules regarding the appropriate use of mentorships and preceptorships, please see Orange Guide Chapter 2: Detailing to HCPs. If you have any questions about Pfizer’s Patient Authorization language, please contact your Regional Attorney. 142 Rev. 09/12 Page 9 of 18
Consent Forms and Mentorships Orange Guide – Chapter 8: Privacy: Protecting Personal Information Q. Does a patient have to sign a written consent form before I can observe an examination or treatment as part of a mentorship, or is verbal permission sufficient? A. Oral permission is not acceptable. As a convenience to your HCP mentor, you can download a template Patient Authorization Form from PfieldNet for the HCP to use. Ultimately, it is the responsibility of the HCP to obtain the appropriate written authorization from the patient. Handling Patients' Personal Data Remember, you must also wear your Pfizer name tag at all times during mentorships. Pfizer-Sponsored Third Party Communications to Patients Occasionally, and within strict limitations, Pfizer pays entities such as managed care organizations and retail pharmacies to mail Pfizer-approved disease management or educational materials to patients who have agreed to receive such mailings from the managed care organization or pharmacy. Pfizer may also pay for medication compliance mailings to certain consenting patients in order to inform or remind them of the schedule to fill or refill a prescription for a chronic medication. These payments are made in accordance with applicable state and federal laws. These types of activities must be documented in a written Service Agreement between Pfizer and the managed care organization or pharmacy. Pfizer Legal Counsel must approve the form of the Service Agreement in advance. The Service Agreement is designed to ensure protection of patients’ privacy as well as compliance with applicable laws and Company policy. The Service Agreement requires the applicable pharmacy or health plan to guarantee and certify that it has permission to send the Pfizer-approved information to the recipients. The Service Agreement also requires the sender to adhere to Pfizer’s personal data protection policies. Among other things, this obligates the health plan or pharmacy to refrain from disclosing to Pfizer any patient names, addresses or other Sensitive Personal Information. Only the pharmacy or health plan can have access to this information. In instances where a third-party mailing 143 Rev. 09/12 Page 10 of 18
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