White Guide and Orange Guide Formatting Project - Pfizer

Orange Guide – Chapter 4: Federal Employee Interactions and Lobbying
donation as long as they are delivered through the VA’s normal channel of distribution (i.e., not from
Sales representatives directly to HCPs).
VA Appointment Requirement
Providing Starters to the VA
Q. Do Sales Colleagues have to make an appointment before calling on HCPs who
work at VA facilities?
A. Yes. Under the new VA rules, VA institutions have incorporated this
requirement into their local site rules. Additionally, once on-site you may only
detail HCPs with whom you have made an appointment.
Q. I’ve been told by an HCP at a VA facility that pharmaceutical companies can
leave starters with the Chief of Pharmacy at the VA. Why does Pfizer’s policy
prohibit this?
A. VA policy permits “free goods” to be donated to the VA. To do this, the free
goods must be delivered through the VA’s normal channel of distribution – not
from sales representatives. In addition, in most cases, the donation must be
pre-approved by the Chief of Pharmacy and the local P&T Committee and the
starters cannot be labeled as professional samples. The distribution of starters
to VA facilities by colleagues does not comply with this policy and is prohibited.
Gifts to Federal Employees (HCPs at VA and DoD Facilities)
Under federal gift rules, a federal government employee may not accept any single gift that has a retail
value of more than $20, nor can a federal government employee accept an aggregate value of more
than $50 in gifts (retail value) from a single “source” given over a consecutive 12 month period. Pfizer,
not each individual colleague, is considered the “source” of the gift when determining whether the $50
limit has been reached. In order to avoid having to track the value of all gifts given to HCPs employed
by the federal government and to ensure that Pfizer maintains compliance with the federal rules at all
times, the only “gifts” that colleagues can provide to federal HCPs are Pfizer approved educational
items and modest meals under the circumstances outlined in this Chapter.
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