White Guide and Orange Guide Formatting Project - Pfizer

Orange Guide – Chapter 4: Federal Employee Interactions and Lobbying
Key Points to Ensure Compliance
Always check local VA or DoD site rules, which may be more restrictive than the guidelines set
forth in this Chapter.
If local site rules permit providing meals, then the following conditions must also be met:
On-site at DoD Facilities:
o Meals may not be offered on a regular, repeated or routine basis to an HCP or
group of HCPsThe total value of a single meal cannot exceed $20 per HCP;
o The total value of all meals and educational items during a calendar year cannot
exceed $50 per HCP; and
o DoD employees must confirm in advance that they are permitted to accept an in-
office or in-hospital meal under the Standards of Ethical Conduct and the local site
rules.
On-site at VA Facilities you may not provide meals of any type or value to VA staff (including
volunteers) or bring food into VA facilities for use by non-VA staff even if given approval by
staff.
Speaker program meals may only be provided to an HCP employed by a federal institution in
connection with a “widely attended gathering” as described in this Chapter.
Modest refreshments can be offered to federally-employed HCPs (except for VA employees
and volunteers) when incidental to a scheduled meeting or legitimate educational
interchange not otherwise prohibited by the facility or local rules. Modest refreshments are
not considered “gifts” and do not count toward the $50 annual cap for each government HCP.
However, if you offer them as part of a meal, then they will count towards the $50 annual cap
and will be considered a “gift.”
Always check the State Laws: HCP and State Employee Restrictions chapter for additional
guidance.
75
Rev. 09/12
Page 5 of 25