White Guide and Orange Guide Formatting Project - Pfizer

State Laws
Orange Guide – Chapter 19: Sales Activities: Greenstone and Pfizer Injectables
State laws on providing meals and other items of value
Note that the rules in certain states may be more restrictive than the PhRMA Code. For example,
effective July 2009, the State of Vermont enacted laws which significantly restrict Pfizer’s ability to
provide meals and other items of value to Vermont HCPs. They apply to all colleagues and extend to
interactions occurring with Vermont HCPs in and outside the State of Vermont. Further, the Vermont
definition of HCP is much broader than the PhRMA Code definition. The Vermont definition of HCP
includes any person licensed to prescribe products or authorized to recommend prescribed products
and any person authorized to dispense or purchase for distribution prescribed products. For more
information on whether your activities are implicated by state laws, see Orange Guide Chapter 17: State
Laws: HCP and State Employee Restrictions or contact your Legal Counsel.
State pharmaceutical compliance and disclosure laws
A growing number of states are requiring companies to monitor their annual expenditures relating to
marketing activities to comply with annual spending limits and disclosure requirements. Since the
passage of Minnesota’s marketing disclosure and restriction law in 1993, several other states including
California, Nevada, Maine, Massachusetts, Vermont, West Virginia, as well as the District of Columbia,
have enacted laws imposing varying spending limitations and disclosure requirements on companies
that market prescription products in those states. In addition, some states require price reporting of
AMP and Best Price to state government agencies. For more information on whether your activities are
implicated by state pharmaceutical compliance and disclosure laws, see Orange Guide Chapter 17:
State Laws: HCP and State Employee Restrictions or contact your Regional Attorney.
State law example: Vermont law
Q. Does the law apply to account directors who support our generics business and
who deal with buyers at large customers?
A. Yes. The Vermont restrictions apply to all colleagues interacting with any
persons authorized to dispense prescribed products or purchase prescribed
products for distribution (as these persons are included in the definition of
HCP).
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Rev. 09/12
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