White Guide and Orange Guide Formatting Project - Pfizer

Orange Guide – Chapter 4: Federal Employee Interactions and Lobbying
Leaving Educational Items with Public Employees
Q. If I leave RC-approved, nominally priced educational (PhRMA Code compliant)
items with an HCP at a federal prison, do I have to track it? What about a state
prison system?
A. Yes. Under Pfizer’s HCP Payment Disclosure Policy, educational items valued
$10 or more must be disclosed and items valued less than $10 may also be
subject to disclosure so all items must be tracked for reporting purposes. Also,
a reporting obligation may be triggered under applicable state law. Because
state laws differ by state, it is imperative that you check with your Regional
Attorney before leaving any item with an HCP at a state prison.
HCPs Who Sit on State Formulary Committees
State-Specific Laws
Q. One of the physicians I call on also happens to sit on a state formulary review
committee. If I am calling on this physician to discuss his private practice only,
and not his role on the state formulary review committee, must I treat him
differently than any other physician who does not sit on a formulary
committee?
A. Maybe. The extent to which HCPs who sit on state formulary committees can
interact with pharmaceutical representatives varies widely, depending on the
specific laws in your state. Check with the relevant Regional Attorney to ensure
your interactions are compliant with applicable state law.
There are two types of lobbying disclosure laws enacted by states that may require you to record and
report certain information. The first category is similar to the federal LDA and requires Pfizer to report
on a regular basis the lobbying activities undertaken in or directed towards a particular state. The
second category affects colleagues who meet with certain state officials or state employees.
States’ General Lobbying Disclosure Laws
Pfizer has a State Government Affairs program which is active in almost all 50 states. As part of this
effort, Pfizer Inc. and/or Pfizer colleagues have registered as lobbyists and have reporting requirements
similar to those on the federal level. The laws differ in each state. Depending on the particular state
law, if you participate in Pfizer’s grassroots advocacy programs and other interactions with state
government officials or public employees, Pfizer may be required to register you as a lobbyist or make
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