White Guide and Orange Guide Formatting Project - Pfizer

Orange Guide - Chapter 18: Meals, Educational Items, and HCP Payment Disclosure
Recording Disclosable Payments and Items
Colleagues MUST properly record all payments, meals (including the number and classification of
attendees), and all other disclosable items, regardless of value, as part of the regular expense reporting
process. Colleagues are expected to:
Obtain full and complete names for all U.S.-licensed HCPs receiving payment for, or
otherwise participating in, activities involving disclosable items, including attendees at
meetings, presentations and speaker programs where meals are provided;
Ensure that they accurately record information about payments and non-cash items
given to U.S.-licensed HCPs in the appropriate system (e.g., Ariba ePay and Purchase
Orders; PT&E’s “My HCP” category; EZSpeak’s “Attendee & Guests” sections; GEMS’
Attendee registry);
Classify budgets and expenses to the appropriate codes and ensure invoices can be
attributed to the HCP through the Pfizer Physician ID Number; and
Never approve expense reports or invoices that are lacking full names and appropriate
expense allocation.
Identifying HCP Meal Attendees in Sales Colleague Expense Reports
Q. A Sales Colleague has provided an in-office meal to a mixed group including
physicians both on and not on her TCL, as well as office staff. Which individuals
must the Sales Colleague identify by name in her meal expense report?
A. Any individuals who are licensed to prescribe medicines in the U.S., including
physicians, Physician Assistants, Nurse Practitioners and Residents, must be
identified by name in the meal expense report, regardless of whether they
appear on the colleague’s TCL. Non-prescribers, including Registered Nurses
and office staff, do not need to be identified by name, except that any
individuals who are employees or agents of a Massachusetts-licensed or
D.C.-licensed prescribers (including non-prescribing nurses and office staff), as
well as MA and D.C. pharmacists, must be named for state reporting purposes.
For further information regarding appropriate use of the travel & expense
system, Sales Colleagues should consult the Pfizer Travel & Expense guidelines
available on PfieldNet. Please also see Orange Guide Chapter 17 for further
details on who qualifies as an HCP in Massachusetts and D.C.
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