White Guide and Orange Guide Formatting Project - Pfizer

Orange Guide – Chapter 15: Non-Rebate Managed Care Customer Interactions
Co-Promote agreements cannot compensate a customer for engaging in routine formulary-related
communications. Routine communications are those that the customer would do with or without
financial support from Pfizer. Examples of routine communications that cannot be funded may include:
Monthly patient newsletters;
The annual mailing of the new formulary guide; and
Routine updates to the formulary which announce all the changes to the formulary since the
last update, based on our rebate contracts.
Generally, Pfizer can fund mailings that are unique to Pfizer and announce only the information related
to Pfizer’s product or the relevant therapeutic category. As with other promotional mailings, Pfizer
must compensate the customer only for the FMV of the services determined on a per-letter basis and
all materials mailed must disclose Pfizer sponsorship and be reviewed and approved by the appropriate
Pfizer Review Committee. Additionally, such programs must be vetted by CGC Legal to ensure
compliance with relevant privacy laws. This analysis may hinge on other factors such as the nature of
the communication, the manner in which the Pfizer product is identified or implied, the audience to
whom the communication would be targeted, the information used to target the message and the
nature of the remuneration and/or expenses covered by Pfizer.
Collaborations
A Collaboration is an arrangement between two or more parties who jointly work together towards a
common goal. Periodically, Pfizer engages its customers in collaborations on various health initiatives
of mutual interest and value to both companies that have potential benefits to the health community at
large. Unlike a Service Agreement, which is more of a vendor-type relationship (Pfizer paying FMV for
a service), a Collaboration Arrangement documents a transaction of a more significant nature that
involves resources provided by each partner. All Collaborations should be supported by an internal
Pfizer business rationale or justification. All collaborations should be discussed, reviewed and approved
by a Regional Attorney or CGC Legal Attorney. Collaborations with not-for-profit entities are
addressed in Pfizer’s Standard Operating Procedure (SOP) entitled Funding Requests for Not-for-Profit
Organizations.
231
Rev. 09/12
Page 5 of 6