White Guide and Orange Guide Formatting Project - Pfizer
White Guide and Orange Guide Formatting Project - Pfizer
White Guide and Orange Guide Formatting Project - Pfizer
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<strong>Orange</strong> <strong>Guide</strong> - Chapter 18: Meals, Educational Items, <strong>and</strong> HCP Payment Disclosure<br />
Tracking <strong>and</strong> Calculating the Disclosable Value of Meals<br />
Q. I am planning to provide a meal at an informational presentation that will be<br />
attended by six U.S. licensed HCPs <strong>and</strong> four other appropriate attendees<br />
(e.g., <strong>Pfizer</strong> colleagues or appropriate HCP office staff). I intend to spend $120.<br />
How will the meal be disclosed?<br />
A. The total value of the meal will be divided by the total number of people who<br />
actually attend your meeting. Therefore, if all ten individuals attend, $12 will be<br />
disclosed for each of the U.S. HCPs licensed to prescribe medicine. However, if<br />
only eight individuals attend, $15 will be disclosed for each of the HCPs.<br />
Q. Do the same disclosure rules apply to meals provided to U.S. HCPs at speaker<br />
programs?<br />
A. Yes. <strong>Pfizer</strong>’s disclosures will include all items of value that are provided in<br />
connection with speaker programs (excluding overhead or similar facility<br />
expenses). The value of meals will be allocated among all attendees. The value<br />
of speaker fees <strong>and</strong> speaker travel expenses will only be allocated to the<br />
speaker.<br />
Q. I am planning for 10 HCPs to attend a speaker program at a restaurant that, as<br />
part of its room reservation contract, requires a $75 meal cost per attendee<br />
commitment ($75 x 10 = $750), regardless of actual attendance. If 2 HCPs do<br />
not show up, will that increase their allocated meal value ($750 / 8 = $93.75)?<br />
A. No. If a restaurant requires <strong>Pfizer</strong> to pay a fixed “per person” meal fee based on<br />
estimated attendance at a speaker program, that “per person” fee will be<br />
allocated to all actual attendees (regardless of actual consumption). In this<br />
example, the 8 HCPs would be allocated $75 each.<br />
Q. If a U.S. HCP attends a meeting or presentation at which a meal is offered but<br />
elects not to consume any food or beverages, can the HCP avoid being<br />
allocated a portion of the meal for disclosure?<br />
A. It depends. If the expenses <strong>and</strong> HCP attendees will be recorded in a <strong>Pfizer</strong><br />
system that permits including only those consuming the meal (e.g., PT&E),<br />
then non-consuming HCPs may not be disclosed. However, if the <strong>Pfizer</strong> system<br />
does not currently allow this distinction (e.g., EZSpeak), then all HCPs will be<br />
disclosed regardless of actual consumption.<br />
299<br />
Rev. 09/12<br />
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