White Guide and Orange Guide Formatting Project - Pfizer

Orange Guide - Chapter 18: Meals, Educational Items, and HCP Payment Disclosure
2009. The March 2010 disclosure included payments and non-cash items valued at $25 or more, and
identified prescribers who received an aggregate of $500 or more during the reporting period.
Pursuant to the CIA, beginning with Pfizer’s March 2011 disclosure of data for the entire 2010 calendar
year, Pfizer is now reporting all disclosable payments, meals and non-cash items, regardless of value,
provided to U.S. licensed prescribers who receive in excess of $100 during a calendar year. For those
who do not pass this annual threshold, only payments and other transfers valued at $10 or more are
disclosed. These de minimus and aggregate threshold rules align with those set forth in the
transparency provisions of the federal Patient Protection and Affordable Care Act, commonly known as
the “Sunshine Act”. Also pursuant to the CIA, after March 2011, Pfizer began issuing its public
disclosures on a quarterly basis. The first quarterly disclosure occurred on June 1, 2011, covering the
first quarter of 2011.
Pfizer believes that our current HCP payment disclosures are in significant alignment with the Sunshine
Act. However, if and to the extent final Sunshine Act regulations and requirements vary from our
current HCP payments disclosure policies and procedures, Pfizer will implement any changes necessary
to comply with those requirements.
Pfizer’s disclosure policy affects any Colleague who provides payments, meals or non-cash items of
any value to licensed U.S. prescribers, U.S. clinical investigators or U.S. institutions. Colleagues
must be familiar with the policy and must personally and proactively discuss our disclosure policies
with all U.S. prescribers to whom they intend to provide disclosable payments or items of value, to
ensure they are aware they will be disclosed.
Stakeholders Affected By Policy
Pfizer’s disclosure includes applicable payments and non-cash items given to the following:
U.S. HCPs who can prescribe medicines, including physicians, nurse practitioners and
physician assistants;
Major institutions involved in clinical trials ongoing as of July 1, 2009; and
Principal investigators and other entities for clinical trials beginning on or after July 1, 2009.
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