White Guide and Orange Guide Formatting Project - Pfizer

Orange Guide – Chapter 17: State Laws: HCP and State Employee Restrictions
Helpful Point
If you are not sure whether an HCP is employed by the State of Colorado or just affiliated with a
state institution, you must confirm his or her relationship with the state prior to providing any meals
or items of more than nominal value to the HCP. If the HCP receives regular compensation directly
from a state institution, he or she is likely considered a state employee and is therefore subject to
the restrictions discussed in this section.
If you have any questions, please contact the Regional Attorney with responsibility for Colorado.
Connecticut
The Law: Connecticut Compliance Program Law
Requires pharmaceutical, biological, and medical device companies to adopt and implement
a marketing code that is at least as restrictive as the PhRMA Code and a comprehensive
compliance program.
Connecticut Department of Consumer Protection has authority to investigate alleged
violations of the code-adoption requirement and alleged failures to conduct any training
program or regular audit for compliance with the adopted code. Violations of the provisions
would subject a company to a civil penalty of not more than $5,000.
District of Columbia
The Law: Prescription Drug Marketing Costs Disclosure Law
The District of Columbia (D.C.) Prescription Drug Marketing Costs Disclosure Law requires Pfizer to
report all marketing costs for prescription drugs to the D.C. Department of Health, including the value,
nature, purpose and recipient of all expenses associated with advertising, marketing, and direct
promotion to D.C. residents through radio, television, magazine, newspaper, direct mail and telephone.
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Rev. 09/12
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