White Guide and Orange Guide Formatting Project - Pfizer

Orange Guide - Chapter 18: Meals, Educational Items, and HCP Payment Disclosure
Disclosure of Snacks and Refreshments Provided at Exhibit Booths
Q. We are planning to have an exhibit booth at a state physicians’ annual
convention, at which we intend to make coffee and pastries of nominal value
available. Do I need to track and report the snacks/refreshments provided to
U.S. physicians visiting the Pfizer booth?
A. Currently, yes. Although not considered a “meal” for purposes of the PhRMA
Code, snacks and refreshments of any value (including nominal value) are
categorized as meals for purposes of Pfizer’s HCP Payment Disclosure policy.
You must ensure that you can accurately record the full name, title, credentials
and address of each prescribing HCP that accepts a snack/refreshment,
including the value of the items provided.
Disclosure of the Value of Educational Items and Non-Disclosure of Patient Materials
As discussed in this Chapter, under Pfizer’s policies and PhRMA Code guidelines, RC-approved
educational items valued at $100 or less may be provided on occasion to U.S. HCPs. The value of these
educational items (such as textbooks and anatomical models) provided to U.S. HCPs are included in
Pfizer’s public disclosures.
Generally, Pfizer-created branded and unbranded promotional materials, literature and other leave
behind written materials are NOT subject to disclosure. Likewise, items that are of value to patients are
NOT disclosable but must be tracked for business purposes. These non-disclosable items include:
Co-pay cards
Savings cards
Pill dispensers
Brochures
Vouchers
Prescription stamps
Pamphlets
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Rev. 09/12
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