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White Guide and Orange Guide Formatting Project - Pfizer

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Key Points to Ensure Compliance<br />

<strong>Orange</strong> <strong>Guide</strong> – Chapter 13: Health Screenings<br />

Only provide health screenings in accordance with the guidelines in this chapter.<br />

o Do not design your own program for a customer.<br />

o Do not modify approved health screening tools.<br />

o Do not alter or customize materials in any way for a customer.<br />

Offer approved health screenings without any expectation of return to <strong>Pfizer</strong>.<br />

o Do not condition the offer of a health screening on increased prescribing or<br />

improved formulary status.<br />

o Do not offer health screenings as an inducement to place <strong>Pfizer</strong> products on<br />

formulary.<br />

Make health screenings widely available.<br />

o Do not choose customers to receive screenings based on their likelihood to<br />

prescribe <strong>Pfizer</strong> products or in return for previous prescribing.<br />

Health screenings cannot be tied to the use of <strong>Pfizer</strong> products in any way.<br />

o You may seek information about products or programs used by those participating<br />

in the screenings, but you may not use such information to promote the use of<br />

<strong>Pfizer</strong> products. For further information on appropriate consumer interactions, see<br />

Chapter 16: Consumer <strong>and</strong> Employee Interactions.<br />

Screenings Offered to an Employer for its Employees<br />

Screenings should be funded out of your promotional budget <strong>and</strong> approved by your CGC Regional<br />

Manager or Sales Director. You should not offer health screenings to employers who are healthcare<br />

providers or payers of healthcare items <strong>and</strong> services, such as hospitals, clinics, medical practice groups<br />

<strong>and</strong> Managed Care Customers (MCCs) who seek reimbursement from the federal government, except<br />

for employers who may receive a government retiree drug subsidy for retirees. Unless otherwise<br />

approved by your Regional Attorney or CGC Legal, the screening must be limited to current employees<br />

214<br />

Rev. 09/12<br />

Page 3 of 8

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