White Guide and Orange Guide Formatting Project - Pfizer

Orange Guide – Chapter 15: Non-Rebate Managed Care Customer Interactions
Medication Compliance Programs
Medication Compliance Programs, most commonly referred to as "refill reminder" or “adherence call”
programs, are outreach programs directed at patients providing them with information about the
product they are taking and reminding them of the importance of staying on therapy and to refill their
prescription in order to get the full benefit of their medication.
To ensure that a Pfizer customer is not improperly profiting from providing the disease management or
medication compliance services Pfizer is paying for, which could be considered an improper
inducement under the anti-kickback laws, the Service Agreement must follow several important rules:
Where Pfizer provides the materials, the compensation to the customer must be equal to
the FMV cost of conducting the reminder program.
Where the customer creates the materials, the compensation to the customer must be equal
to the FMV cost of creating and conducting the reminder program.
Where possible, the FMV amount should be determined on a per-letter basis or per
interaction basis and, as appropriate, the amount should be validated through internal
benchmarking or an FMV assessment project.
In addition to the above, all materials provided as part of either a Patient Education or
Medication Compliance Program must be reviewed and approved by a Pfizer Review
Committee.
Co-Promote Programs
Subject to HIPAA or any state medical marketing law requirements, Pfizer may enter into Service
Agreements with customers for the distribution of non-routine formulary information about Pfizer
products to a customer’s members. Typically, these contracts compensate a customer for providing
information to its members explaining that a Pfizer product has recently been added to the customer’s
formulary or reminding them of the availability of Pfizer products on formulary.
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