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 />
Underst<strong>and</strong>ing the Opt-Out Process<br />
Public Disclosures<br />
Q. Can a Sales colleague provide a meal to an office with multiple HCPs if some<br />
HCPs have opted out <strong>and</strong> others have chosen not to opt-out?<br />
A. Generally, yes. However, any HCPs in the office who have opted out must not<br />
be provided the meal.<br />
Q. Can a Sales colleague provide a meal for office staff if all the HCPs (prescribing<br />
<strong>and</strong> non-prescribing) in an office have opted out?<br />
A. No.<br />
Q. What happens if an HCP who has previously opted out later eats a meal that I<br />
provided for other HCPs in the office or at a joint meeting or event?<br />
A. You must inform the HCP that any meals consumed will be reported, <strong>and</strong> you<br />
must include the HCP in the list of attendees in the relevant expense system<br />
(e.g., PT&E) for allocation of an appropriate portion of the meal to the HCP.<br />
<strong>Pfizer</strong>’s duty to report meals that it provides to HCPs is non-negotiable.<br />
Q. What happens if an HCP who has previously opted out attends a speaker<br />
program at which a meal is provided?<br />
A. All speaker program attendees will be allocated a portion of the meal<br />
regardless of actual consumption <strong>and</strong>, accordingly, the HCP will be disclosed as<br />
having received the meal. Speaker event invitations <strong>and</strong> attendee sign-in<br />
sheets include language advising attendees of this policy.<br />
Q. I have an HCP that is willing to perform consulting services for zero<br />
compensation, including no travel payments. Will this arrangement be subject<br />
to disclosure?<br />
A. Probably not. In most cases, the HCP must still be required to sign a “zero fee”<br />
consultant agreement to memorialize the terms. Please contact<br />
ENGAGE2@pfizer.com or your team attorney with any questions.<br />
<strong>Pfizer</strong>’s disclosures separately identify payments <strong>and</strong> non-cash items provided to each U.S. licensed<br />
prescriber or U.S. institution by category, including meals, educational items, business-related travel<br />
expenses, professional advising (i.e., consulting fees) <strong>and</strong> expert-led forums (i.e., speaker fees). The<br />
disclosures are posted on <strong>Pfizer</strong>’s website at<br />
http://www.pfizer.com/responsibility/working_with_hcp/working_with_hcp.jsp.<br />
303<br />
Rev. 09/12<br />
Page 19 of 21
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