White Guide and Orange Guide Formatting Project - Pfizer

Orange Guide – Chapter 14: CGC Tools and Resources
legitimate reasons as determined by CGC Legal and the Channel Strategy & Solutions Group), the
proposed modifications must be approved by a Pfizer Review Committee before being provided to a
customer. Keep in mind that Quality Programs that underwrite operational services or provide services
that the customer would be obligated to obtain on its own will not receive approval by the Pfizer
Review Committee.
The Value of Quality Programs in Meeting Objectives
Quality Program Recipients
Q. I know I cannot conduct a financial return on investment (ROI) analysis on
Quality Programs since they are not to be tied to prescribing. Can I conduct any
analysis to determine whether the Quality Program was valuable to the
customer?
A. Non-financial ROI analyses, like measuring whether a program has improved
patient or physician understanding of a disease or enhanced the ability of
physicians to effectively discuss sensitive issues with patients, are appropriate
to conduct in order to determine whether the Quality Program met its objective
of improving patient outcomes or increasing physician understanding.
Quality Programs must be made widely available to our customers who meet certain capability criteria
as part of Pfizer’s overall mission to enhance the quality of healthcare. Offering the programs to only
select customers could be perceived as providing items of value in order to increase prescribing or
improve formulary status in violation of the anti-kickback laws or other healthcare laws.
To ensure that the offering of these programs does not violate applicable law, you must never provide a
Quality Program to a customer in exchange for increased prescribing or improved formulary status.
Even though a customer may decide to change prescribing habits or formulary status based on the
information it receives from a Quality Program, you should never make these changes a condition of
receiving the program.
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