White Guide and Orange Guide Formatting Project - Pfizer

Orange Guide - Chapter 18: Meals, Educational Items, and HCP Payment Disclosure
Key Points to Ensure Compliance (cont’d)
Until further notice, the cost of meals provided at speaker programs is allocated among all
attendees, regardless of actual consumption (i.e., U.S. prescribers who are present at a
speaker program where a meal is provided can not “opt out” of having a proportionate value
of the meal allocated to them).
Colleagues must ensure that they correctly record information necessary to identify a
prescriber and payments or items of value conferred in the applicable finance and payment
system(s), for accurate attribution of compensation or other value for disclosure purposes.
Except for meals provided at speaker programs, a U.S. prescriber may “opt-out” of being
offered meals, snacks or educational items by contacting PTI@Pfizer.com. (“Opt-out”
prescribers may also “opt back in” by contacting the mailbox.) Colleagues that interact with
HCPs are responsible for verifying their “opt-out” status. Sales Colleagues should consult the
physician profiles on their iCUE tablet to view an HCP’s “opt out” status. For all colleagues, an
“opt-out” list is also maintained on OpSource and PfieldNet.
If a U.S. prescriber has “opted-out” but still accepts payments, meals or other disclosable
items of value from Pfizer, the prescriber will be subject to disclosure accordingly.
There are also certain state laws and federal institutions (e.g., VA/DoD) that limit and/or
require the disclosure of payments and other items provided to HCPs. These laws and
restrictions are described in the State Laws: HCP and State Employee Restrictions Chapter
and the Federal Employee Interactions and Lobbying Chapter. Additional information is also
available on Opsource under the “State Healthcare Law Compliance” tab and on PfieldNet
under the “Compliance” tab.
In-scope payments or other exchanges of value provided to U.S. licensed prescribers and U.S.
institutions through approved third party entities, such as Contract Research Organizations
(CROs) and Contract Sales Organizations (CSOs), remain subject to disclosure.
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Rev. 09/12
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