White Guide and Orange Guide Formatting Project - Pfizer

Orange Guide - Chapter 18: Meals, Educational Items, and HCP Payment Disclosure
Key Points to Ensure Compliance
Unless further restricted by state law, food and beverages provided by any Pfizer colleague to
HCPs must be modest by local standards. In no event may the cost spent on food and
beverages exceed $135 per attendee, including tax and tip.
When providing a modest meal in connection with product promotion, the meal must never
serve as the primary focus of the interaction – it should be incidental to the dissemination of
approved information and must comply with the PhRMA Code.
It is improper for colleagues to provide “take out” meals to HCPs or their staff members.
The PhRMA Code prohibits Sales representatives and colleagues who supervise one or more
Sales representatives from hosting any out-of-office meal for HCPs (outside of speaker
programs). Senior Sales Colleagues (above District Manager) and non-Sales colleagues
(including Marketing) are not subject to this restriction and may host restaurant or other
meals, as long as there is a “legitimate business purpose” for hosting the meal.
The PhRMA Code prohibits non-educational items from being offered to U.S. HCPs or
members of their staff. Accordingly, only Pfizer Review Committee-approved
(“RC-approved”) educational items may be provided to HCPs and their staff.
Pfizer’s payment disclosure policy applies to payments, meals, snacks, reimbursable travel
expenses and approved educational items provided to U.S. licensed prescribers, including
physicians, nurse practitioners and physician assistants. Pfizer also discloses payments to
U.S. institutions in connection with clinical research, along with the names of corresponding
principal investigators.
Pfizer’s disclosures are posted on the Pfizer public website at
http://www.pfizer.com/responsibility/working_with_hcp/working_with_hcp.jsp.
For meals provided in connection with an informational presentation or consultant meeting,
the disclosable value is calculated by taking the total cost of the meal and dividing it by the
number of attendees.
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Rev. 09/12
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