White Guide and Orange Guide Formatting Project - Pfizer

Orange Guide – Chapter 4: Federal Employee Interactions and Lobbying
Key Points to Ensure Compliance
Only Review Committee approved (“RC-approved”) nominally priced educational materials
may be provided to a government HCP. It is your responsibility to ensure that the annual
aggregate value of all meals and educational items to a government HCP from Pfizer does not
exceed $50 annually.
At VA facilities, you must submit educational materials to the Chief of Pharmacy Services at
least 60 days prior to your educational program or meeting. Additionally, asbsent permission
from VA Pharmacy Benefits Management Service, patient education materials may not
contain the name or logo of the manufacturer or promote a specific medication.
You must learn the sample policies of any institution that you call on and follow those rules,
unless they conflict with Pfizer policy or the Prescription Drug Marketing Act (PDMA).
Federally-employed HCPs may be hired to speak on Pfizer’s behalf only if they receive prior
approval by their agency before accepting such an outside engagement and if the HCP:
o Determines that the speaking engagement does not conflict with his or her official
duties;
o Is speaking in his or her individual capacity and not as an employee of the
government;
o Is not using his or her government position or title to identify himself or herself at
the speaker program;
o Is speaking because he or she is a subject matter expert on a topic;
o Is not speaking on a matter pending before his/her government agency or
institution, or any matter which the employee was assigned during the previous
one year period;
o Is taking personal time to speak rather than speaking during government time; and
o Is not disclosing any non-public or government confidential information.
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Rev. 09/12
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