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White Guide and Orange Guide Formatting Project - Pfizer

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Referencing Quality Programs During Formulary Discussions<br />

<strong>Orange</strong> <strong>Guide</strong> – Chapter 14: CGC Tools <strong>and</strong> Resources<br />

Q. If a Managed Care Organization’s formulary decision maker asks me for<br />

additional reasons why a <strong>Pfizer</strong> product should be included on its formulary,<br />

may I discuss the quality <strong>and</strong> variety of our Quality Programs?<br />

A. No. A Quality Program may never be offered as a reason for including a <strong>Pfizer</strong><br />

product on formulary. The quality program may be perceived as an item of<br />

value offered to increase prescribing in violation of the anti-kickback laws.<br />

Consequently, you must never affirmatively discuss a Quality Program in<br />

relation to a formulary decision. If a customer makes an unsolicited inquiry<br />

about the availability of Quality Programs, you may address it by:<br />

FOR MORE INFORMATION<br />

Stating that at the conclusion of your product discussion you can provide<br />

information about the Quality Programs that <strong>Pfizer</strong> makes available to<br />

its customers; <strong>and</strong><br />

Stating that an offer or provision of a Quality Program to the customer is<br />

in no way influenced by the customer’s pending formulary decision.<br />

Consult the CGC intranet site at http://mmweb2.pfizer.com for information <strong>and</strong> guidance on<br />

CGC Tools <strong>and</strong> Resources, as well as a listing of available Quality Programs.<br />

Questions may be referred to your manager, the Customer Marketing Group, your Regional<br />

Attorney or CGC Legal Team.<br />

226<br />

Rev. 09/12<br />

Page 7 of 7

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