Living With a Corporate Integrity Agreement

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Presentation transcript:

Living With a Corporate Integrity Agreement 2003 Pharmaceutical Congress June 9 Doug Lankler

The Pfizer CIA Five year term Commenced October 2002 Approximately 220 “Covered Persons” Managed Care Contracting Sales Force that deals with Managed Care Legal Division Grants team Two IRO engagements

The Pfizer CIA (Cont’d) Relevant Conduct $250,000 grant Legacy Warner Lambert issue: conduct focused on two colleagues No Pfizer involvement No relevant employees still with Company Different systems Legacy WL systems displaced by Pfizer systems

Before the Agreement Keep in mind: inherited liabilities A strong program helps Watch the news; ask if it can happen at your company Voluntary disclosure protocol Audit against Sentencing Guidelines; Model Guidance Audit health care law systems

After the Agreement: What Works Make sure everyone knows about the CIA and understands its impact Frequent reminders “Normalize” the CIA Test your systems Get the IRO in early Understand the differences between your CIA and others

After the Agreement: What Works (cont’d) Stay in close touch with HHS OIG Have Internal Audit do a dry run of the engagement(s) Computerize your training systems Multi-disciplinary committee/task force Involve Board; keep them involved Document everything When in doubt, ask

Deputy Corporate Compliance Officer Questions/Contact Info Doug Lankler Sr. Corporate Counsel Deputy Corporate Compliance Officer Pfizer Inc 235 East 42nd Street New York, NY 10017 212.733.0752 Douglas.Lankler@Pfizer.com