White Guide and Orange Guide Formatting Project - Pfizer

Orange Guide – Chapter 17: State Laws: HCP and State Employee Restrictions
Physician Assistants;
Certified nurse midwife;
Psychiatric nurse mental health specialists;
Nurse Practitioners; and
Employees and agents of such persons (e.g., nurses, office staff, etc.)
HCP does not include hospitals, nursing homes, pharmacists, health benefit plan administrators,
healthcare professionals not licensed in Massachusetts, and other entities if they are not agents,
employees, etc. of a MA-licensed HCP. (However, such entities are considered Covered Recipients for
MA disclosure, as described below.)
How the Law Impacts Your Activities
All colleagues (regardless of division, business unit, or role) who engage in activities with Massachusetts
licensed HCPs, regardless of where the HCP practices or where the interaction occurs, should be aware
that Massachusetts laws restrict Pfizer’s ability to provide meals and other items of value to
Massachusetts HCPs. In addition, certain expenditures have to be reported, so all colleagues must
ensure that their records on these expenditures are accurate and complete.
You must make a good faith effort to determine whether an HCP is licensed in Massachusetts. To help
you determine whether an HCP holds a MA license, you should check the HCP License List available on
Opsource under the State Healthcare Law Compliance tab. Sales Colleagues can also access this
information on PfieldNet under the Compliance Tab or by looking up the HCP in their iCUE tablet.
Meals
The Massachusetts Marketing Code of Conduct is more restrictive than the PhRMA Code with respect
to the provision of meals to HCPs.
Meals must be “on-site”. In other words, meals are only permissible during informational
presentations in an HCP office or in-hospital setting (a cafeteria located within a hospital
would generally qualify as a hospital setting). Meals must be modest and occasional.
The restriction applies to all colleagues – not only Sales and Marketing.
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Rev. 09/12
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