Vermont Compliance Officer Registration

By Casra Afshordi

On December 6th, the 2016 Vermont Compliance Officer registration form was posted.

It is now an online form rather than a pdf. template. Companies with 2016 Vermont expenditures are required to use this form to register with the Vermont Attorney General’s Office and pay an annual registration fee of $500 by January 1, 2017. Vermont expenditures and distribution of samples for 2016 are to be reported no later than April 1, 2017.

Companies need to send a check made payable to “State of Vermont” for $500 by January 1, 2017 to:

Office of the Attorney General
Attn. Public Protection Division
109 State Street
Montpelier, VT  05609-1009

Vermont law bans most gifts and requires manufacturers of prescribed products, including pharmaceuticals, biological products, and medical devices, to “disclose allowable expenditures and permitted gifts given to Vermont healthcare providers.” Vermont law also requires manufacturers to disclose the distribution of samples of prescribed products to Vermont HCPs. Under Vermont law, a “sample” includes starter packs, coupons, and vouchers that enable an individual to receive a prescribed product free of charge or at a discounted price.

Although some of this information might be captured in Federal transparency reporting, this is an additional annual reporting requirement specific for the State of Vermont. If companies send a registration fee and later determine that no expenditures or samples were distributed to Vermont recipients during 2016, companies may request a refund for the $500 fee from the State after April 1, 2017.

Again, the online form can be reached at:

If you have any questions or concerns on this requirement, please don’t hesitate to contact the Polaris Aggregate Spend and Transparency team.