White Guide and Orange Guide Formatting Project - Pfizer

Orange Guide – Chapter 17: State Laws: HCP and State Employee Restrictions
Health plan benefit administrators; and
Members of the Green Mountain Care Board (whether or not they are licensed HCPs).
How the Law Impacts Your Activities
All colleagues (regardless of division, business unit or role) who engage in activities that involve
Vermont HCPs, regardless of where the HCP practices or where the interaction occurs, should be aware
that Vermont prohibits Pfizer from providing meals and certain other items of value to Vermont 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 Vermont. To help you
determine whether an HCP holds a VT license, you can check the HCP Lookup 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
All meals to Vermont HCPs are prohibited. This prohibition includes the provision of coffee and donuts,
or other food items of nominal value, even if these items are for non-prescribing staff in a physician’s
office. There is a limited exception for meals provided as compensation to Vermont HCPs who are
providing services pursuant to a bona fide contract with Pfizer. In addition, refreshments such as coffee
and snacks provided by Pfizer at a booth at a convention/congress are also permissible.
Gift Ban
In addition to the prohibition on meals, colleagues cannot provide Vermont HCPs with any item of
value unless the item is explicitly allowed under the law.
The following items are allowed under Vermont law:
Starters;
Peer-reviewed academic, scientific, or clinical articles or journals that have been
RC-approved;
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Rev. 09/12
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