White Guide and Orange Guide Formatting Project - Pfizer
White Guide and Orange Guide Formatting Project - Pfizer
White Guide and Orange Guide Formatting Project - Pfizer
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<strong>Orange</strong> <strong>Guide</strong> - Chapter 1: Overview <strong>and</strong> Key Principles<br />
Anti-Kickback Laws: Prohibit improper influence on healthcare decisions by making it a crime to<br />
knowingly <strong>and</strong> willfully give or receive anything of value in order to influence or obtain government<br />
healthcare business.<br />
Best Price Law: Prohibits charging Medicaid more than the lowest price (i.e., “best price”) at which<br />
<strong>Pfizer</strong> offers a product to any other customer. <strong>Pfizer</strong> must calculate <strong>and</strong> report to the federal<br />
government our “best price” for each product.<br />
False Claims Act: Prohibits making or inducing someone else to make a false claim for<br />
reimbursement from the federal government.<br />
This Chapter provides an overview of some of the key laws, regulations, guidance, <strong>and</strong> industry<br />
codes that apply to our business. The policies contained in this <strong>Guide</strong> are designed to ensure that<br />
your activities comply with these laws, regulations, guidance, industry codes, our CIA, <strong>and</strong> State<br />
Attorneys General Agreements.<br />
Non-compliance with these policies can subject <strong>Pfizer</strong> colleagues to disciplinary action up to <strong>and</strong><br />
including termination. Further, improper activities that violate one or more of these laws <strong>and</strong><br />
regulations could result in criminal <strong>and</strong> civil penalties for you <strong>and</strong> the Company.<br />
If the application of any policy is unclear to you, discuss the issue with your manager or team attorney.<br />
Overview of Key Healthcare Laws <strong>and</strong> Regulations<br />
Anti-Kickback Laws<br />
An HCP’s treatment decisions should not be tainted by motives of personal gain or enrichment. The<br />
anti-kickback laws seek to prohibit improper influences on healthcare decisions by making it a criminal<br />
<strong>and</strong>/or civil offense to knowingly <strong>and</strong> willfully solicit, receive, offer to pay, pay, or provide anything of<br />
value in order to influence or obtain government healthcare business. These laws prohibit payments<br />
intended to induce someone to purchase, prescribe, endorse or recommend a product that is<br />
reimbursed under federal or state healthcare programs. For example, the anti-kickback laws prohibit<br />
such activities as:<br />
Providing a gift to an HCP (including a pharmacist) to influence the prescribing, dispensing,<br />
or recommending of pharmaceutical products;<br />
4<br />
Rev. 09/12<br />
Page 4 of 15
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