White Guide and Orange Guide Formatting Project - Pfizer

Orange Guide – Chapter 17: State Laws: HCP and State Employee Restrictions
In addition, Pfizer may only provide CME support (through the MEG process and standards) to
conference organizers that meet ACCME standards or equivalent standards. Pfizer may not, however,
provide funding directly to support meals for HCPs or compensate HCPs for attending CME events.
Helpful Points
Colleagues must not invite MA licensed HCPs to Pfizer speaker programs that provide food unless
the program occurs in an HCP’s office or a hospital setting (even if the program is conducted outside
of Massachusetts).
Subject to further notice from Legal, do not provide MA HCPs with any meal or snacks outside an
office or hospital setting. Remember that any food provided in an office or hospital setting must be
part of an informational presentation.
There is an exception for meals provided as compensation under valid consulting agreements and
for refreshments provided in a convention/congress booth.
Colleagues must make a good faith effort to determine whether an HCP is licensed in MA before
inviting an HCP to a speaker program and can consult PfieldNet for a list of MA HCPs or iCUE for
assistance.
The meal and gift restrictions apply even when a MA HCP is located in another state.
Disclosure
Pfizer must track and report annually all expenditures made to Covered Recipients for sales and
marketing activities in excess of $50 (per transaction). The definition of “Covered Recipients” is broader
than the definition of HCPs and includes hospitals, nursing homes, pharmacists and health benefit
administrators. Therefore, even though pharmacists are not prohibited from receiving meals (because
they are not included in the definition of HCP), they are subject to the disclosure requirements since
they are considered Covered Recipients, so certain payments to pharmacists must be disclosed. The
only expenditures that do not need to be disclosed are those associated with rebates and discounts,
genuine research, clinical trials, demonstration units, and starters. That data will be made publicly
available on the state’s website.
Effective July 8, 2012, co-pay cards, coupons and free trial vouchers may be provided to MA residents or
to providers or pharmacies for distribution to MA residents, subject to the following:
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