White Guide and Orange Guide Formatting Project - Pfizer

Providing Health Screening Data to a CGC Customer
Orange Guide – Chapter 13: Health Screenings
Q. One of my CGC customers wants Pfizer to conduct a disease screening for
employees of an employer to whom the customer provides pharmacy benefits.
The customer also wants Pfizer to provide them with the de-identified,
aggregate data from the screening. Can I organize the screening and provide
the data?
A. Maybe. The only reason you can conduct a disease screening is to improve
patient care. You cannot subsidize the operating expenses of the customer or
the employer by conducting a screening that they would do on their own. If
there is an independent valid reason for Pfizer to fund the screening, Pfizer can
organize it. Aggregated, de-identified data from the screening can only be
provided to the customer if each employee screened signs Pfizer's Patient
Authorization and Release and if it specifically provides that the data can be
provided to both the employer and the managed care plan administering the
drug benefit. Employees of the MCC are not eligible to participate in the
screening and the MCC should not appear as a co-sponsor of the event unless
the MCC independently provides funding or services.
Screenings Offered to the Public at Large
If organized by a Hospital, Non-Profit Organization, Managed Care Organization or Other Third
Party:
Pfizer’s Medical Education Group (MEG) can support a screening organized by a third party
through an unrestricted educational grant, provided that the event meets Pfizer's
requirements for unrestricted educational grants. You must NEVER promise that a grant
will be provided for a health screening or for any other reason. The requestor must apply
directly to MEG for funding, and will receive notice from MEG regarding whether the
request has been approved.
The requesting organization is solely responsible for logistics and content of the event.
The screening event must be advertised and open to the community at large (e.g.,
advertised in the newspaper or on TV or radio).
The screening must not be organized or designed in any way to generate referrals for any
particular customer.
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Rev. 09/12
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