White Guide and Orange Guide Formatting Project - Pfizer

Orange Guide - Chapter 10: Starters
By law, pharmaceutical companies may provide starters only to licensed HCPs with authority to
prescribe medication or, at the prescriber’s direction, to the pharmacy of the institution in which the
licensed HCP works. Only a licensed HCP may sign a request for starters. The authority to prescribe
and/or accept starters varies by state. Certain restrictions may apply to mid-level HCPs (e.g., NPs and
PAs) and their ability to prescribe and/or receive starters within their state.
In addition, some states have particular limitations on distributing starters for controlled substances
like Lyrica. Sales Colleagues should check with their manager, Starter Operations, or their Regional
Attorney if they have questions about who can receive particular Pfizer starters in their state.
Starters cannot, under any circumstances, be provided to an HCP:
If the HCP intends to seek reimbursement from the government for the starter;
If the HCP is within an excluded medical specialty;
If the HCP intends to use the starter for his or her personal use;
To reward the HCP for past prescribing or as a financial inducement for future prescribing;
If it is reasonably certain that the HCP intends to prescribe the starters for an off-label use;
or
If the prescriber’s license number has not been verified in iCUE.
Sales Colleagues may not initiate any starter transactions with an HCP until the State License Number
(SLN) for that HCP is “verified” as valid in iCUE.
In the past, other pharmaceutical companies and individuals have been charged under the False Claims
Act and the anti-kickback laws, and fined hundreds of millions of dollars, for encouraging HCPs to bill
government programs for starters. For this reason, HCPs must confirm their understanding and
acceptance of the fact that starters “cannot be sold, traded, bartered, returned for credit or utilized
to seek reimbursement” by signing the eSAF (or paper SAF, in those limited circumstances where
paper SAFs are permitted).
Pfizer policy further provides that Sales Colleagues must witness the signature on Starter Activity
Forms.
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Rev. 09/12
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