th655 15 Street, N.W. Washington, DC 20005-5701 Tel: (202) 452-8444 Fax: (202) 429-4519 E-mail: fmi@fmi.org Web site: www.fmi.org November 25, 2002 Office of the Inspector General Department of Health and Human Services Attention: OIG-8-CPG Cohen Building 330 Independence Avenue, S.W. Washington, D.C. 20201 Re: Draft OIG Compliance Program Guidance for Pharmaceutical Manufacturers (File Code OIG-8-CPG) Dear Inspector General: The Food Marketing Institute (FMI) respectfully submits the following comments in response to the draft compliance document developed by the Department of Health and Human Services (HHS) Office of Inspector General (OIG) for the pharmaceutical manufacturing industry. 67 Fed. Reg. 62057 (Oct. 3, 2002). For your information, FMI is a non-profit association that conducts programs in research, education, industry relations and public affairs on behalf of its 2,300 members and their subsidiaries. Our membership includes food retailers and wholesalers, as well as their customers, in the United States and around the world. FMI’s domestic member companies operate approximately 26,000 retail food stores with a combined annual sales volume of $340 billion, which represents three-quarters of all grocery store sales in the United States. FMI’s retail members also operate close to 12,000 in-store pharmacy departments. We estimate that supermarket pharmacies account for nearly 14 percent of all ...