• Healthcare professionals,
• Academic institutions,
• Non-profit hospital foundations,
• Educational, and patient organizations located in or providing services in Vermont; and
• Members of the Green Mountain Care Board

• Samples (separate disclosure template)
• Device loaners (allowed for up to 120 days)
• Clinical and research payments
• Compensation for bona fide services
• Sponsorship and fellowship payments
• Educational materials
• Demo/evaluation units
• Coupons, vouchers and discount cards
• Charitable contributions

Data points to be disclosed:

• Manufacturer’s name
• Recipient’s name
• License number of recipients
• Date of expenditure
• Value of expenditure
• Nature of expenditure
• Purpose of expenditure
• Product type and name

“Manufacturer” means a pharmaceutical, biological product, or medical device manufacturer or any other person who is engaged in the production, preparation, propagation, compounding, processing, marketing, packaging, repacking, distributing, or labeling of prescribed products.

• The term “Manufacturer” does not include a wholesale distributor of biological products, a retailer, or a pharmacist licensed under 26 V.S.A. chapter 36.
• The term also does not include a manufacturer whose only prescribed products are classified as Class I by the U.S. Food and Drug Administration, are exempt from pre-market notification under Section 510(k) of the federal Food, Drug and Cosmetic Act, and are sold over-the-counter without a prescription.

• The Compliance Officer Form must be completed and submitted by the first day of each reporting period – e.g. by January 1, 2021, by manufacturers with expenditures in 2020 with a registration fees of $500.
• The AGO provides Excel spreadsheets for both Expenditure and Sample disclosures, once completed the spreadsheets should be emailed to [email protected]

ago.vermont.gov/disclosures manufacturers-prescription-drugs-biological-products-medical-devices/