White Guide and Orange Guide Formatting Project - Pfizer

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Orange Guide - Chapter 18: Meals, Educational Items, and HCP Payment Disclosure Host restaurant meals? Host in-office meals? Host in-hospital meals? Host speaker programs? Host meals at conventions? District Manager No Yes Yes Yes No Regional Manager, Regional Director, Regional Presidents Yes Yes Yes Yes Yes HQ Marketing/Medical Yes Yes Yes Yes Yes Furthermore, several states and the VA/DoD also impose meal limitations and reporting requirements that are stricter than the PhRMA Code and/or Pfizer’s HCP Payment Disclosure policy. For instance, with very limited exceptions (such as meals provided in connection with certain HCP services), no meals (in- or out-of-office) may be provided to physicians licensed to practice in Vermont or Minnesota, and no out-of-office meals may be provided to physicians licensed to practice in Massachusetts (pending further notice from Legal). The VA, in particular, also prohibits colleagues from providing food items of any type or value to VA staff (including volunteers) at VA facilities or bringing food into VA facilities for use by non-VA staff, even if a colleague receives approval from on-site staff. Before providing any meals or other items of value to HCPs, colleagues should refer to the Chapters on State Laws: HCP and State Employee Restrictions and Federal Employee Interactions and Lobbying. To determine whether an HCP is licensed in Massachusetts, Minnesota or Vermont, Sales representatives should consult the physician profile on their iCUE tablet, and other colleagues should consult the HCP License List at http://hcplookup.pfizer.com/Pages/search.aspx. Additional information on State law restrictions and other tools are available on under the Compliance tab on PfieldNet and under the State Healthcare Law Compliance tab on OpSource. Meals Provided by Field Sales Colleagues and Their Managers Under the PhRMA Code, any meals provided to U.S. HCPs by Sales representatives and their immediate managers in connection with informational presentations must be limited to in-office and in-hospital settings. The only time a representative or his/her immediate manager may provide a 290 Rev. 09/12 Page 6 of 21
Orange Guide - Chapter 18: Meals, Educational Items, and HCP Payment Disclosure restaurant meal to an HCP is at a Pfizer speaker program where an approved speaker (generally a paid external HCP) is presenting RC-approved educational information about Pfizer product(s), disease state(s) or other healthcare topic(s), where the content is controlled by Pfizer. Sales representatives and their managers are prohibited from providing out-of-office meals to HCPs in all other circumstances. Presentations made by a Pfizer employee (such as an Account Manager) who is not specifically authorized to conduct a promotional presentation to HCPs do not constitute a speaker program. It is also impermissible to pay for a meal at an activity which does not consist of Pfizer controlled content, such as at an independent continuing medical education program. (For more information about speaker programs, see the Orange Guide Chapter 9: Speaker Programs for HCPs, and White Guide Chapter 4: Marketing Programs.) It is inappropriate for a Sales representative to include an HCP’s spouse or other guest in any Pfizer-provided meal unless the spouse or guest is an appropriate HCP or office staff member themselves, who is otherwise permitted to attend the meal. It is never appropriate for a Sales representative to offer “take-out” meals or meals to be eaten without the representative present. PhRMA Code “Meals” Defined Q. What is considered a “meal” under the PhRMA Code? A. Anything more than nominal food or beverage item is considered a meal and, thus, may not be provided by Sales representatives outside of an office or hospital setting unless in connection with a speaker program. Q. Does taking an HCP out for a cup of coffee constitute a meal? A. No. In accordance with the PhRMA Code, food or beverage items of nominal value – such as coffee, other non-alcoholic beverages, pastries or snacks – are not considered to constitute a meal. Pfizer policy permits a Sales representative to make an educational presentation to an HCP out of the HCP’s office or hospital (such as in a coffee shop near the HCP’s office) over such nominal food or non-alcoholic beverage, unless further restricted by state law or other laws or policies. In all cases, however, the value of any food or beverages, regardless of amount, provided to a U.S. licensed physician is subject to public disclosure by Pfizer, and the Pfizer colleague must appropriately record the expense as described in this Chapter. 291 Rev. 09/12 Page 7 of 21
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White Guide and Orange Guide Formatting Project - Pfizer

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