White Guide and Orange Guide Formatting Project - Pfizer

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.
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Rev. 09/12
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