White Guide and Orange Guide Formatting Project - Pfizer

Promotional Activities
Orange Guide – Chapter 4: Federal Employee Interactions and Lobbying
Impact of Formulary Status on Ability to Promote
Sales Colleagues must comply with any federal institution’s local requirement that only products on
formulary or those that do not comply with VAs criteria-for-use be discussed with its HCPs. Products
that are not on the VA National Formulary must be specifically approved by the Veterans Integrated
Services Network, the Chief of Pharmacy or a designee. In some cases, local regulations will prohibit
any discussion of products that are either not on the institution’s formulary or that are on the formulary
with restrictions. In all cases, you must accurately and clearly represent the formulary status of the
product being discussed.
Promotional Materials
You must make an appointment with individual HCPs prior to calling on VA facilities. Do not leave
promotional materials in patient areas. In addition, be aware of rules pertaining to how you are
expected to conduct yourself when leaving promotional materials for HCPs at federal institutions. For
example, VA facilities do not permit marketing to students (including residents), paging employees via
a public address/paging system unless specifically asked by the employee or waiting in patient-care
areas.
Starters
Many government institutions, such as VA clinics and hospitals, may prohibit pharmaceutical
companies from leaving starters. Other government institutions that do accept starters generally
require them to be provided to the Chief of Pharmacy and not to individual HCPs. As noted above, you
must always learn the sample policies of any institution that you call on and follow those rules, unless
those rules conflict with Pfizer policy or the PDMA. If a Sales Colleague has questions about whether a
customer’s sample policies are consistent with Pfizer policies on starter distribution, contact Starter
Administration or the relevant Regional Attorney before leaving starters with that customer.
Even if intended for use in private practice, starters should not be left for VA DoD HCPs at the
government institution in which they work. However, “free goods” may be provided to the VA as a
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