White Guide and Orange Guide Formatting Project - Pfizer

Distribution of Starters to Colleagues for Personal Use
Orange Guide - Chapter 10: Starters
Q. If a colleague is suffering from an infection and he or she asks a Sales Colleague
for one or two doses of an antibiotic that the Colleague promoted while on a
field ride, is it ok to provide it?
A. No. It is not permissible to give any person, even a colleague, any starter for his
or her personal use. This could be considered practicing medicine without a
license under various state laws. If a colleague makes such a request of a Sales
Colleague, he or she must decline and report the request to his or her (or
another) manager, Regional Attorney or through the Corporate Compliance
Hotline. Failure to bring such a request to Pfizer’s attention, or knowingly
giving any starter away for personal use, is a violation of the Duty to Act and a
violation of Pfizer policy and the law.
Hospitals, VA and DoD Institutions
Sales Colleagues are permitted to provide starters to hospitals and other healthcare institutions that
use them in the treatment of their patients. In all cases, Sales Colleagues must deliver the starters to an
HCP eligible to receive the starters on behalf of the hospital or institution (this would include the
pharmacist in charge of handling starters for the hospital).
Some hospitals and healthcare institutions have policies that require starters to be left in the pharmacy
and not with the individual physicians who have requested them. Sales Colleagues may do this only
after completing a dual-signature paper “In House Pharmacy” Starter Activity Form. This form is
used to document the physician’s request for starters and the pharmacist’s receipt of the starters in the
institution pharmacy. The “In House Pharmacy” Starter Activity Form can be ordered from Starter
Operations by calling Standard Register at 800-313-8263 and following the caller-directed prompts. As
further described in this Chapter, for Sales Colleagues using an iCUE tablet, this is one of only two very
limited exceptions under which a paper SAF may be used.
Meanwhile, many government institutions, such as Department of Veterans Affairs (VA) clinics and
hospitals, may prohibit pharmaceutical companies from leaving starters. Other government
institutions that do accept starters generally require them to be provided to the Chief of Pharmacy and
not to individual physicians. Even if intended for use in private practice, starters should not be left for
VA or Department of Defense (DoD) physicians at the government institution in which they work. For
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