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Living With a Corporate Integrity Agreement

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

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Living With a Corporate Integrity Agreement

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

  2. 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

  3. 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

  4. 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

  5. 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

  6. 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

  7. 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

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