White Guide and Orange Guide Formatting Project - Pfizer

More documents

Recommendations

Info

Orange Guide - Chapter 18: Meals, Educational Items, and HCP Payment Disclosure provide modest food or beverages to HCPs in restaurants or other appropriate venues (such as Pfizer’s offices) as long as there is a “legitimate business reason” for hosting the meal. (While Sales representatives and their immediate managers may attend meals hosted by such colleagues, they should not use them as a means to conduct activities or events that they cannot host on their own. Further, for all Sales Colleagues, it is presumed that discussions regarding unapproved indications for Pfizer products, or disease state or treatment areas for which Pfizer has no product, are impermissible and thus cannot constitute a “legitimate business reason” for an HCP meal interaction. Sales Colleagues should consult with their Regional Attorney with any questions regarding whether the topic(s) to be discussed at proposed HCP meal are appropriate.) In order to determine whether the “legitimate business reason” requirement is satisfied, these colleagues should determine whether the proposed interaction and meal is consistent with their role and responsibilities and whether the interaction helps them satisfy (in a legitimate way) their goals and objectives. The central focus must be the business interaction, with the meal being incidental to that primary purpose. At all times, colleagues must exercise sound judgment and discretion when providing meals in conjunction with a business interaction. Any questions about whether a meal can be provided to an HCP should be directed to the relevant team attorney. Legitimate Business Reason Educational Items to HCPs Q. Pfizer is hosting a promotional booth staffed by Marketing Colleagues at a medical conference. Can a Marketing Colleague take a group of physicians out to a restaurant meal to discuss new Pfizer RC-approved data on a Pfizer product? A. Yes. This would be considered a “legitimate business purpose” since it is certainly permissible for Marketing Colleagues to discuss RC-approved content with HCPs so long as they adhere to the Four Core Compliance Principles. Marketing colleagues may continue to provide a modest meal incidental to the discussion (unless restricted by state law). For more information, see the Chapter on State Laws: HCP and State Employee Restrictions. In accordance with the PhRMA Code and Pfizer policy, RC-approved educational items valued at $100 or less may be provided on occasion to HCPs or members of their staff. Non-educational items are prohibited from being offered, even if the items are practice-related and of minimal value (such as 294 Rev. 09/12 Page 10 of 21
Orange Guide - Chapter 18: Meals, Educational Items, and HCP Payment Disclosure pens, pads, mugs, etc.). If you have a question about whether a specific educational item is still approved to provide to HCPs, consult the relevant product Legal or Regulatory colleague, or submit your question to PhrmaCode@pfizer.com. Further, like meals, several states and the VA/DoD also impose limitations on educational items (and other items of value) that may be provided to HCPs that are stricter than the PhRMA Code and/or Pfizer’s HCP Payment Disclosure policy. For instance, to ensure compliance with Minnesota state law, Pfizer policy prohibits colleagues from providing educational items to physicians licensed to practice in that state. Before providing educational items to HCPs, colleagues should refer to the Chapters on State Laws: HCP and State Employee Restrictions and Federal Employee Interactions and Lobbying. For further information, and to determine whether an HCP is licensed in Minnesota, consult the HCP License List and other references available on Opsource under the “State Healthcare Law Compliance” tab and on PfieldNet under the Compliance tab. Sales Colleagues should also consult the State Law Restiction field on their iCUE tablet. Out-of-Pocket Gifts for HCPs Q. Can I pay for a gift for an HCP out of my own pocket if I do not expense it? A. No. It is not appropriate to purchase personal gifts of any kind for HCPs in the course of doing business, even if you pay out-of-pocket and do not seek reimbursement from Pfizer. The gesture can too easily appear to be an attempt to illegally influence prescribing in violation of anti-kickback laws. Remember that Pfizer Policies of Business Conduct require you to avoid even the appearance of a conflict of interest. HCP Payment Disclosure Policy Overview Pfizer has committed to publicly disclose payments and the value of meals, reimbursable travel expenses and educational items that it provides to U.S. licensed prescribers and institutions. That commitment has been memorialized and expanded as part of Pfizer’s August 2009 Corporate Integrity Agreement (CIA). On March 31, 2010, Pfizer made its first disclosure of payments, meals and other non-cash items provided to prescribers, covering the period between July 1, 2009 and December 31, 295 Rev. 09/12 Page 11 of 21
Page 1 and 2:
Dear Colleagues: Pfizer Inc 235 Eas
Page 3 and 4:
To expand the bookmarks for a chapt
Page 5 and 6:
Orange Guide - Chapter 1: Overview
Page 7 and 8:
Page 9 and 10:
Page 11 and 12:
Page 13 and 14:
Page 15 and 16:
Foreign Corrupt Practices Act Orang
Page 17 and 18:
Pfizer’s Corporate Integrity Agre
Page 19 and 20:
Page 21 and 22:
Orange Guide - Chapter 2: Detailing
Page 23 and 24:
Key Points to Ensure Compliance Ora
Page 25 and 26:
Page 27 and 28:
Communicating Formulary Status Mail
Page 29 and 30:
Page 31 and 32:
Page 33 and 34:
Hospital Protocols Comparative Clai
Page 35 and 36:
Page 37 and 38:
Page 39 and 40:
Interacting with RMRS Colleagues Or
Page 41 and 42:
Page 43 and 44:
Page 45 and 46:
Page 47 and 48:
Detailing at Journal Club Meetings
Page 49 and 50:
Orange Guide - Chapter 3: Support o
Page 51 and 52:
Page 53 and 54:
Page 55 and 56:
Medical Education Grants Overview O
Page 57 and 58:
International Grant Activity Orange
Page 59 and 60:
Page 61 and 62:
“Not-for-Profit” Defined Orange
Page 63 and 64:
Page 65 and 66:
Page 67 and 68:
Information on Pfizer’s External
Page 69 and 70:
Overview Orange Guide - Chapter 3:
Page 71 and 72:
Awards, Scholarships and Fellowship
Page 73 and 74:
Page 75 and 76:
Orange Guide - Chapter 4: Federal E
Page 77 and 78:
Page 79 and 80:
Page 81 and 82:
Promotional Activities Orange Guide
Page 83 and 84:
Page 85 and 86:
Speaker Program Meals Part-Time VA
Page 87 and 88:
Page 89 and 90:
Page 91 and 92:
Page 93 and 94:
Page 95 and 96:
Page 97 and 98:
Page 99 and 100:
Page 101 and 102:
Orange Guide - Chapter 5: Interacti
Page 103 and 104:
Page 105 and 106:
Page 107 and 108:
Page 109 and 110:
Page 111 and 112:
Page 113 and 114:
Page 115 and 116:
Discussing Payer Rebates Medical Ac
Page 117 and 118:
Page 119 and 120:
Orange Guide - Chapter 6: Clinical
Page 121 and 122:
Page 123 and 124:
Page 125 and 126:
Page 127 and 128:
Orange Guide - Chapter 7: P&T Commi
Page 129 and 130:
Page 131 and 132:
Questions From a P&T Committee Memb
Page 133 and 134:
Page 135 and 136:
Page 137 and 138:
Page 139 and 140:
Orange Guide - Chapter 8: Privacy:
Page 141 and 142:
Page 143 and 144:
Page 145 and 146:
Seek Only De-Identified Data Orange
Page 147 and 148:
Consent Forms and Mentorships Orang
Page 149 and 150:
REMEMBER Orange Guide - Chapter 8:
Page 151 and 152:
Proper Use of HCP Prescriber Data O
Page 153 and 154:
Page 155 and 156:
Page 157 and 158:
Orange Guide - Chapter 9: Speaker P
Page 159 and 160:
Page 161 and 162:
Speaker Selection Scheduling Issues
Page 163 and 164:
Use of Pfizer Approved Speaker Slid
Page 165 and 166:
Page 167 and 168:
Page 169 and 170:
Providing In-Office Meals to Office
Page 171 and 172:
U.S. HCP Payment Disclosure Policy
Page 173 and 174:
Page 175 and 176:
Closeouts Orange Guide - Chapter 9:
Page 177 and 178:
Page 179 and 180:
Physical Separation of Speaker Prog
Page 181 and 182:
Chapter 10: STARTERS CONTENTS Start
Page 183 and 184:
Page 185 and 186:
Orange Guide - Chapter 10: Starters
Page 187 and 188:
Inclusion of Materials with Starter
Page 189 and 190:
Page 191 and 192:
Distribution of Starters to Colleag
Page 193 and 194:
Page 195 and 196:
Page 197 and 198:
Page 199 and 200:
Orange Guide - Chapter 11: Patient
Page 201 and 202:
Page 203 and 204:
Page 205 and 206:
A special note about Medicare Part
Page 207 and 208:
Refer any questions to your team at
Page 209 and 210:
Chapter 12: CONTRACTING Introductio
Page 211 and 212:
Orange Guide - Chapter 12: Contract
Page 213 and 214:
Orange Guide - Chapter 12: Contract
Page 215 and 216:
Page 217 and 218:
Chapter 13: HEALTH SCREENINGS Intro
Page 219 and 220:
Orange Guide - Chapter 13: Health S
Page 221 and 222:
If organized by Pfizer: Orange Guid
Page 223 and 224:
Orange Guide - Chapter 13: Health S
Page 225 and 226:
Orange Guide - Chapter 14: CGC Tool
Page 227 and 228:
Orange Guide - Chapter 14: CGC Tool
Page 229 and 230:
Discussing Pfizer Products While Me
Page 231 and 232:
Orange Guide - Chapter 15: Non-Reba
Page 233 and 234:
Page 235 and 236:
Page 237 and 238:
Orange Guide - Chapter 16: Consumer
Page 239 and 240:
Page 241 and 242:
Page 243 and 244:
Providing Food to Consumers at a Di
Page 245 and 246:
Page 247 and 248: Content of Consumer Slide Decks Att
Page 249 and 250: Adverse Events Orange Guide - Chapt
Page 251 and 252: Orange Guide - Chapter 17: State La
Page 263 and 264: California Orange Guide - Chapter 1
Page 277 and 278: Educational Items Orange Guide - Ch
Page 289 and 290: Orange Guide - Chapter 18: Meals, E
Page 293 and 294: Meals to HCPs Orange Guide - Chapte
Page 297: Orange Guide - Chapter 18: Meals, E
Page 311 and 312: Orange Guide - Chapter 19: Sales Ac
Page 313 and 314: Pricing Considerations Orange Guide
Page 321: Orange Guide - Chapter 19: Sales Ac
show all

White Guide and Orange Guide Formatting Project - Pfizer

Create successful ePaper yourself

Delete template?

Save as template?