White Guide and Orange Guide Formatting Project - Pfizer

Speaker Program Meals
Part-Time VA Employees
Educational Items
Orange Guide – Chapter 4: Federal Employee Interactions and Lobbying
Q. A Sales Colleague has invited a DoD HCP to a speaker program that qualifies as
a “widely attended gathering.” If the DoD HCP attends the speaker program
after confirming in writing with her employer that attendance is in the best
interest of the agency, is it permissible for the DoD HCP to receive the same
meal as the other attendees if it’s more than $20 in value? Or, is Pfizer required
to provide a meal of $20 or less in value?
A. If a VA or DoD HCP attends a widely attended gathering with the permission of
their employer, the meal is considered exempt from the federal gift limitations.
Q. One of my customers works three days a week at his private practice and two
days a week at a VA hospital. When I provide him meals at his private office,
am I required to follow the VA/DoD limitations set forth in the Orange Guide?
A. It depends. HCPs who work part-time for the VA are still required to follow the
policies of the VA as if they are full-time employees. You should verify with
your customer if he is employed by the VA, or if he is an independent
contractor, in which case the rules governing interactions with VA employees
may not apply. If your customer is an independent contractor or if you are not
sure of his status, check with the ethics counselor of the government facility
and/or your Regional Attorney to ensure compliance.
Remember that when given to a VA or DoD HCP, the value of the RC-approved educational item may
not exceed $20 and the total aggregate of all gifts (meals and educational items) for the calendar year
to each HCP cannot exceed $50. 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.
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