White Guide and Orange Guide Formatting Project - Pfizer

Orange Guide – Chapter 15: Non-Rebate Managed Care Customer Interactions
Non-compliance with these policies puts the Company at risk and can subject you to disciplinary
action up to and including termination of employment.
Key Points to Ensure Compliance
Do not discuss Service Agreements or other arrangements in connection with rebate
negotiations.
Service Agreements should not reference existing rebate contracts in any way.
Do not enter into Service Agreements for the purpose of inducing the placement or
maintenance of Pfizer products on a formulary.
Only enter into Service Agreements that support an identified Pfizer business need.
All Service Agreements and other arrangements must be approved by CGC Legal.
Only use Pfizer approved templates unless otherwise instructed by CGC Legal.
Arrangements must be consistent with Pfizer’s HITECH Guidance on Brand Marketing
Programs with MCCs.
Patient Education Programs
Patient Education Programs allow Pfizer to provide RC-approved health information to a customer’s
members. By entering into a Service Agreement with a customer, Pfizer is able to reach patients who
are suffering from the conditions which Pfizer products are indicated to treat, which may help them
better manage their condition. Any compensation to the customer under a Service Agreement must be
equal to the Fair Market Value (FMV) cost of developing and/or conducting the services that are being
contracted to provide, e.g., mailing any program materials or welcome kits, as applicable. In addition,
only approved Patient Education materials may be used and the materials must disclose Pfizer’s
sponsorship. Any proposed changes to approved materials must be reviewed and approved by the
appropriate Pfizer Review Committee before the materials can be disseminated.
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Rev. 09/12
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