White Guide and Orange Guide Formatting Project - Pfizer

Orange Guide – Chapter 4: Federal Employee Interactions and Lobbying
Meals in Connection with Promotional Presentations
Colleagues must review the local site rules of any DoD or other federal healthcare facility to determine
whether in-office or in-hospital meals are permissible. When meals are permitted by local rule, in
addition to following any site rules, you must also ensure the following conditions are met:
Meals are not offered on a regular, repeated or routine basis to an HCP or group of HCPs;
Each meal has a total value of $20 or less;
The aggregate value of all meals and educational items given by Pfizer to an HCP during a
calendar year does not exceed $50;
The meal takes place at the HCP’s office or hospital when hosted by a representative or
District Manager; and
The DoD employee confirms that he or she is permitted to accept the in-office or in-hospital
meal under the Standards of Ethical Conduct and local site rules.
Effective April 4, 2012, the VA rule on Drug and Drug-Related Supply Promotion by Pharmaceutical
Company Sales Representatives at VA Facilities prohibits Colleagues from providing in-office or
in-hospital meals to HCPs employed by the VA or their staff (including volunteers).
Sales Colleagues must coordinate with each other to ensure that in total, Pfizer does not provide more
than $50 of value per HCP per year for meals and educational items.
Remember that any meals and educational items provided to HCPs employed by the VA, DoD or any
federal government institution will be subject to Pfizer’s HCP Payment Disclosure Policy. All HCPs,
including those employed by the VA and DoD, may “opt-out” of receiving these items by notifying their
sales representative or by contacting PTI@Pfizer.com. For additional information on Pfizer’s HCP
Payment Disclosure Policy, see Chapter 18: Meals, Educational Items, and HCP Payment Disclosure.
Meals in Connection with Speaker Programs
Meals may also be provided to HCPs employed by the federal government (including VA employees) as
part of an off-site educational speaker program that is a “widely attended gathering” as determined by
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