Yes, all true. But, the Boston US Attorney did almost all the work. That office has specialized in pharma off-label cases.

“The U.S. Attorney’s offices for the District of Massachusetts, the Eastern District of Pennsylvania, and the Eastern District of Kentucky, and the Civil Division of the Department of Justice handled these cases. The U.S. Attorney’s Office for the District of Massachusetts led the criminal investigation of Bextra. The investigation was conducted by the Office of Inspector General for the Department of Health and Human Services (HHS), the FBI, the Defense Criminal Investigative Service (DCIS), the Office of Criminal Investigations for the Food and Drug Administration (FDA), the Veterans’ Administration’s (VA) Office of Criminal Investigations, the Office of the Inspector General for the Office of Personnel Management (OPM), the Office of the Inspector General for the United States Postal Service (USPS), the National Association of Medicaid Fraud Control Units and the offices of various state Attorneys General.

“Our creation of the Executive Compliance Committee will serve as an important addition to our compliance infrastructure, and ensure the dedicated involvement of our senior-most leaders in our continuing efforts to fully integrate compliance and integrity into all that we do at Pfizer,” Jeffs intones in the statement.

Remember this statement because if per chance there is another indiscretion at Pfizer, the fact that the senior-most level is now/finally dedicated to and “involved” in compliance and integrity they should also be involved in the punishment when we see non-compliance and ethical failures in the future.

By the way, JiM, I don’t think that FDA investigators were part of this investigation. It was the US Attorney’s office out of Boston. That office handles most all pharma investigations.

Atlex’s earlier post may also be relevant. If the DOJ even hinted they might move toward the gov. not doing business with Pfizer, it could suggest they had more “on them” than a few rogue middle managers. Likewise, the enormous size of the criminal and civil penalties. In a more limited case, they more typically would have focused on those specific people–without penalizing the entire company to that extent.

Again, I’m not suggesting I know. I’m suggesting there are many plausible scenarios. All this also happened at a time when this sort of promotion had become pretty common, and companies assumed competitors where doing it, whether they were busted or not (as has come out in court documents related to other cases). That, in turn, coincided with the downsizing of FDA investigation/enforcement during the Bush admin.

I do not mean that higher level people were, therfore, involved. But I also do not take it to mean they were not. There are just too many variables besides how “pissed-off” the DOJ might be.

There are also instances when CEOs have been fined, even served time, when they did not have knowledge. Buck stops, etc..

Re: who was indicted, my understanding accords with yours that DOJ worked hard to identify those individuals most responsible. As many have described, most corporations have folks in the role of “Vice President in Charge of Going to Jail” in order to provide plausible deniability to those higher up the chain.

Whether that was the true in this latest Pfizer case I don’t know.