White Guide and Orange Guide Formatting Project - Pfizer

Paying for Display Space at a Private Practice Event
Call Notes
Orange Guide – Chapter 2: Detailing to HCPs
Q. I received an invitation from one of my specialty practice groups to pay a
display fee to set up an exhibit at the practice's business meeting. Can we pay
for the display?
A. Generally, no. Payments to private practice groups are subject to increased
scrutiny and are generally impermissible, particularly at events exclusively for
members of the practice or events which are aimed at benefiting the practice's
business. However, there may be exceptions to this rule that you should
discuss with your manager or Regional Attorney. For example, payment might
be permissible in a situation where a private practice group is relatively large
and other pharmaceutical companies will be providing an exhibit. Similarly,
payment might be permissible if an event involves the participation of a larger
community of physicians (such as one providing continuing education credit).
Sales representatives are permitted, but not required, to keep “call notes” documenting their details
with HCPs, provided that such call notes are kept solely in iCUE. Any call notes documented in iCUE
should be written in such a way that the context is clear and not misleading to an outside reader.
Preceptorships and Other Training for Sales Colleagues
In limited circumstances, HCPs may be hired to train colleagues where there is a legitimate and unmet
educational need. The need must have a purpose not already met by training provided by Pfizer
Learning & Development and relate to the improvement of sales performance.
You must never pay an HCP to speak to colleagues for the purpose of giving the HCP practice making
presentations or as a way to ensure that the HCP reads certain information. Similarly, you must never
pay an HCP to train colleagues for the purpose of building a relationship with the HCP, gaining or
improving access to the HCP, rewarding past prescribing, or inducing future prescribing.
A “preceptorship” refers to a group learning situation where a group of colleagues meet at a local or
national Center of Excellence to hear presentations from one or more HCPs or observe patient care
situations over the course of a day. The need for these events should be limited, and you should
conduct these events infrequently.
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Rev. 09/12
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