White Guide and Orange Guide Formatting Project - Pfizer

Providing Funding to Customers
Orange Guide – Chapter 19: Sales Activities: Greenstone and Pfizer Injectables
Q. What are the considerations involved in deciding whether I can approve a
donation to a pharmacy’s patient awareness program? The money would fund
the distribution of sunscreen to patients when they fill prescriptions for
medications that increase photo-sensitivity.
A. This request might be considered a discount, which Pfizer or Greenstone might
then need to offer to other customers or consider for its government price
reporting. Any payment or gift to customers also must be considered in light of
potential anti-kickback concerns. Consult with your Legal Counsel about the
propriety of making such a donation.
Q. What if the donation requested would be paid to a foundation or other not-forprofit
organization?
A. Donations to not-for-profit organizations must follow the procedures set out in
the Standard Operating Procedure on Funding Requests for Not-for-Profit
Organizations. However, if a not-for-profit organization is affiliated with a
customer (such as a foundation established by a pharmacy), a donation may
raise potential anti-kickback concerns, and you should consult with your Legal
Counsel.
When a funding request relates to a not-for-profit organization, please refer to Orange Guide Chapter
3: Support of External Organizations. The Standard Operating Procedure (SOP) on Funding Requests
for Not-for-Profit Organizations, available at http://opsource.pfizer.com, applies to all funding to not-
for-profit organizations.
Giveaway Items
The Pharmaceutical Research and Manufacturers of America (PhRMA) Code on Interactions with
Healthcare Professionals (PhRMA Code) prohibits non-educational items from being offered to
practicing HCPs or members of their staff, even if practice-related and of minimal value (e.g., pens,
pads, and mugs). Items of nominal value, such as pens, may be distributed by Greenstone and Pfizer
Injectables at booths at trade shows and conferences, provided that Pfizer brands are not being
represented at such events. Such items must not, under any circumstances, be distributed in the field
(e.g., at hospitals or to practicing pharmacists), nor may these items be made available through the
Promos online catalog or other sources accessible by all colleagues.
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