White Guide and Orange Guide Formatting Project - Pfizer

Orange Guide - Chapter 10: Starters
Vouchers, Co-Pay Relief and Similar Consumer Programs, Updated Free Trial Voucher Policy and
related FAQs.
Improper use of vouchers can implicate the state and federal false claims acts and anti-kickback laws.
Vouchers could also be deemed to impact the “best price” of a product (i.e., the discount the Company
is required to give the Medicaid program on every unit of product it reimburses). For more information,
see White Guide Chapter 6: Government Healthcare Programs.
Key Points for Developing a Voucher Program and Distributing Vouchers
Vouchers must never be offered or provided to HCPs contingent upon the HCP’s past, current
or future prescribing practices;
Vouchers may not be provided to HCPs to substitute for a discount, i.e., contingent upon sale
of the product to that customer;
Vouchers may not be offered to HCPs for personal use; and
Vouchers are a form of product promotion. They may not be offered to HCPs for off-label
uses; nor may they be offered to an HCP that practices in a specialty that is excluded for that
specific product.
FOR MORE INFORMATION
Questions may be referred to Starter Operations, the relevant Sales manager, Regional
Attorney or team attorney.
For Pfizer’s policies for complying with the PDMA, see the Starter Operations Compliance
Manual.
Sales Colleagues who need to order “In House Pharmacy” Starter Activity Forms can obtain
them by calling Standard Register at 800-313-8263.
For more information on the use of product in scientific investigations, see the White Guide
and Orange Guide Chapters on Clinical Research and Investigator-Initiated Research.
For more information on distributing starters in government institutions, see the White
Guide and Orange Guide Chapters on Federal Employee Interactions and Lobbying.
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