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White Guide and Orange Guide Formatting Project - Pfizer

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<strong>Orange</strong> <strong>Guide</strong> – Chapter 17: State Laws: HCP <strong>and</strong> State Employee Restrictions<br />

Helpful Points<br />

Vermont prohibits all meals with VT HCPs (regardless of where the meal takes place) except as<br />

noted below.<br />

Snacks of nominal value (e.g., coffee, drinks, cookies, etc.) are also prohibited, except when<br />

provided at a booth at a convention/congress.<br />

You must not invite VT HCPs to <strong>Pfizer</strong> speaker programs at which food is provided even if the<br />

program is conducted outside of Vermont.<br />

There is an exception for meals provided as compensation for services performed under a bona fide<br />

consulting contract.<br />

You are required to make a good faith effort to determine whether an HCP is licensed in VT before<br />

inviting an HCP to a speaker program. You can consult PfieldNet or Opsource for a list of VT HCPs<br />

or by looking up th HCP in the iCUE tablet.<br />

The meal <strong>and</strong> gift restrictions apply even when a VT HCP is located in another state.<br />

Disclosure<br />

Most allowable expenditures to Vermont HCPs, or other institutions covered by the law (e.g., Vermont<br />

academic institutions), must be disclosed, regardless of the amount.<br />

Effective January 2011, <strong>Pfizer</strong> amended its policies <strong>and</strong> began tracking the distribution of samples,<br />

coupons <strong>and</strong> vouchers. The first disclosure report is due by April 2012. Vermont’s law defines “sample”<br />

as a unit of a prescription drug, biological product or medical device that is not intended to be sold <strong>and</strong><br />

is intended to promote the sale of the drug, product or device, including starter packs <strong>and</strong> coupons or<br />

vouchers that allow any individual to receive a prescribed product for free or at a discounted price.<br />

Items exempt from disclosure are:<br />

Refreshments <strong>and</strong> other snacks provided at a booth at a convention/congress;<br />

Rebates <strong>and</strong> discounts;<br />

Royalties <strong>and</strong> licensing fees for patent rights;<br />

281<br />

Rev. 09/12<br />

Page 35 of 38

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