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White Guide and Orange Guide Formatting Project - Pfizer

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 />

Labels on prescribed products;<br />

Reasonable expenses related to the interview by a manufacturer in connection with a bona<br />

fide employment opportunity; <strong>and</strong><br />

Prescribed products distributed free of charge or at a discounted price pursuant to a <strong>Pfizer</strong><br />

Patient Assistance Program.<br />

The Law: Vermont Price Disclosure Law<br />

The Vermont Price Disclosure Law requires that, when marketing directly to Vermont authorized<br />

prescribers, <strong>Pfizer</strong> disclose the Average Wholesale Price (AWP) “per pill” of each drug marketed, as well<br />

as the prices of other drugs in the same therapeutic class. Two types of disclosure are required:<br />

Long Form Disclosure: Disclosure of price-related information posted on <strong>Pfizer</strong>’s website;<br />

<strong>and</strong><br />

Short Form Disclosure: Written disclosure of price information which must be provided to<br />

the prescriber at the point of specific detailing or promotional activity (whether in person, by<br />

mail, by telephone or electronically). This short form is available at<br />

http://www-stg2.pfizer.com/vtprescribers/mn_shortforms.jsp.<br />

The following table identifies which forms are required in connection with typical promotional<br />

activities.<br />

Promotional Activity Action Required<br />

Face-to-face meeting with prescribers (detailing,<br />

dinner or lunch programs, exhibit booths,<br />

professional conferences) in Vermont.<br />

Provide short form to each prescriber for each<br />

product promoted or detailed.<br />

Mailing to prescribers. Include short form with mailing for each product<br />

promoted.<br />

Telephone calls. Inform Vermont prescriber that short form will<br />

282<br />

be mailed; mail short form for each product<br />

promoted to business address within 24 hours.<br />

Rev. 09/12<br />

Page 36 of 38

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