White Guide and Orange Guide Formatting Project - Pfizer

Orange Guide - Chapter 18: Meals, Educational Items, and HCP Payment Disclosure
Chapter 18: MEALS, EDUCATIONAL ITEMS, AND
HCP PAYMENT DISCLOSURE
Introduction
The Pharmaceutical Research and Manufacturers of America (PhRMA) Code on Interactions with
Healthcare Professionals (PhRMA Code), updated in January 2009, provides that occasional meals may
be offered to U.S. healthcare professionals (HCPs) in connection with informational presentations and
discussions, so long as the meal is modest as judged by local standards and occurs in a venue and
manner conducive to informational communication that provides scientific or educational value. The
PhRMA Code also restricts who may provide out-of-office meals to U.S. HCPs. In addition, it allows
colleagues to give occasional approved educational items to U.S. HCPs if the items are valued at $100
or less.
Meanwhile, in early 2009, Pfizer committed to publicly disclose payments and the value of meals,
reimbursable travel expenses and educational items that it provides to U.S. licensed prescribers,
beginning in 2010. Pfizer also committed to disclose all payments to U.S. institutions in connection
with clinical research, along with the names of the associated principal investigators. These disclosure
commitments were subsequently included and expanded as part of Pfizer’s 2009 Corporate Integrity
Agreement with the Office of Inspector General (OIG) of the U.S. Department of Health and Human
Services. Soon, all pharmaceutical manufacturers operating in the U.S. will be required to report and
disclose payments and other transfers of value to U.S. physicians and U.S. teaching hospitals in
accordance with the transparency provisions of the Patient Protection and Affordable Care Act
(PPACA), which are commonly known as the “Sunshine Act”. HCP payment disclosure is just one of the
many ways Pfizer is working to maintain our commitment to increased transparency and public candor.
This Chapter concerns the provision of payments, meals, educational items or anything of value to
U.S. prescribers or U.S. institutions. Also certain state laws and federal institutions further restrict
or require the disclosure of payments and other items provided to U.S. HCPs, as described in the
State Laws: HCP and State Employee Restrictions Chapter and the Federal Employee Interactions
and Lobbying Chapter. Non-compliance with these policies puts the Company at risk and can
subject Pfizer colleagues to disciplinary action up to and including termination.
286
Rev. 09/12
Page 2 of 21