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Document 12 of 60.

March 21, 2000, Tuesday

SECTION: PREPARED TESTIMONY

LENGTH: 5421 words

HEADLINE: PREPARED TESTIMONY OF CARMEN A. CATIZONE, M.S., R.PH. EXECUTIVE DIRECTOR/SECRETARY NATIONAL ASSOCIATION OF BOARDS OF PHARMACY

BEFORE THE SENATE COMMITTEE ON HEALTH, EDUCATION, LABOR AND PENSIONS

SUBJECT - E-DRUGS: WHO REGULATES INTERNET PHARMACIES?

BODY:
Mr. Chairman and members of the Committee, I am Carmen A. Catizone, Executive Director/Secretary of the National Association of Boards of Pharmacy (NABP). NABP is the professional organization, whose membership consists of the state boards of pharmacy in all jurisdictions of the United States, the Virgin Islands, Puerto Rico, Guam, nine provinces of Canada, three Australian states, and New Zealand. NABP is the international, independent, and impartial Association that assists its member boards and jurisdictions in developing, implementing, and enforcing uniform standards for the purpose of protecting the public health.

It is a privilege to appear before this Committee to provide the information that NABP has acquired through the state boards of pharmacy and our Verified Internet Pharmacy Practice SitesTM (VIPPSTM) program concerning "E-Drugs" and the Regulation of the Internet. The Internet has revolutionized communication worldwide. Its potential to improve health care delivery is unprecedented. However, as members of this Committee are undoubtedly aware, the Internet also presents significant challenges to regulators and a serious potential for harm to consumers. Our interest in the Internet distribution of prescription medications began approximately five years ago. At that time, the state boards of pharmacy and the Food and Drug Administration (FDA) identified, and worked together to eliminate, the illegal distribution of drugs through offshore distributors. Many of these operations were clandestine laboratories distributing counterfeit, outdated, or black market prescription drugs to U.S. consumers. Their principal source of solicitation and delivery was the postal system. The limitations and traceability of a paper-based, postal system coupled with the combined enforcement efforts of the states and FDA, caused these operations to largely disappear until the advent of the Internet.

As millions of U.S. consumers gained access to the Internet, the illegal distribution of prescription drugs outside of the federal and state regulated system resurfaced. The Internet enabled the distribution of prescription drugs through anonymous, electronic, and large volume means. The Internet almost completely disguised the audit trail investigators need to locate and prosecute offenders by virtue of a personal computer and Internet service provider and placed distribution centers in the homes and offices of U.S. consumers.

In your deliberations we ask that you recognize the dichotomy of the Internet to offer innovative ways to provide health care and pose unique concerns for the health and welfare of U.S. citizens. We also ask your support for the authority of the states to regulate the practice of pharmacy. The ability of the states to effectively regulate this complex and ever-changing area is contingent upon sufficient resources, cooperation among the responsible state agencies, and a strong partnership with federal agencies such as the Food and Drug Administration, the Federal Trade Commission, Customs, the Postal Service, and the Department of Justice.

Our joint efforts with state medical boards, the Federation of State Medical Boards, federal agencies, pharmacy associations, the American Medical Association, and regulated entities has created the infrastructure for an effective strike force to combat U.S.-based e- drug sites which present a harm and danger to the public health and welfare. It is our hope this Committee will support our efforts and provide the human and technological resources necessary to provide a safe environment on the Internet where American consumers may confidently use Internet pharmacies for their health care needs.

TESTIMONY BEFORE THE U.S. HOUSE OF REPRESENTATIVES COMMERCE COMMITTEE SUBCOMMITTEE ON OVERSIGHT AND INVESTIGATIONS

On July 30, 1999 we testified before the U.S. House of Representatives Committee on Commerce's Subcommittee on Oversight and Investigations.

At that time we expressed our concern about the availability of prescription medications online and the illegal activities of some Internet sites. Our testimony identified hundreds of Internet sites, operating both legally and illegally in the United States and worldwide. We also discussed with Subcommittee members the practices of legitimate online pharmacy sites and the benefits they offered patients and consumers. Included in that testimony and attached to this document for reference is information explaining NABP's Verified Internet Pharmacy Practice Sites Program (VIPPS), the VIPPS Criteria and definitions, VIPPS Application Form, and a summary of the state laws regarding licensure/registration of out-of-state pharmacies and wholesalers (Attachment A).

Our research at the time of the July 30 hearing differentiated sites into different organizational and operational categories. "Pharmacy- based sites are defined as those sites that do not offer prescribing services and are associated with an identifiable pharmacy licensed/registered by a state board of pharmacy in the United States. Prescribing-based sites are defined as those online outlets that provide medications to consumers utilizing a cyberspace consultation or questionnaire. Almost without exception, the pharmacy-based sites are located in the United States and its territories and regulated by a state agency. The prescribing-based sites are a complex mix of operations, based both in the United States and its territories and foreign countries. The most egregious and dangerous sites NABP identified are certain prescribing-based sites that operate outside the jurisdiction of the United States with little or no regard for the laws and regulations of the states."

THE PRESENT STATUS OF THE INTERNET

In the months since the House Commerce Committee heating, we have continued to monitor online sites and noticed some significant changes in their design, operation, and focus. First and foremost, five sites have earned the VIPPS certificate, representing approximately 8000 pharmacy practice sites, both Internet and traditional brick and mortar entities. We anticipate that the number of seals awarded by the end of the first six months of 2000 will number more than a dozen and the number of pharmacy practice sites represented by those seals will exceed 10,000. NABP has the highest level of confidence that these sites are practicing pharmacy in accordance with state laws and regulations and acceptable standards of care. More information about the VIPPS program and current application status will be presented later in this report.

Secondly, the overall landscape of Internet sites has matured now offering additional benefits to patients and posing some new concerns. The Internet sites currently accessible to the public have also consolidated into more easily defined operational structures that lend themselves to some generalization. All sites can be divided into two major categories, those operating legally and those operating illegally. NABP defines an illegal site as one that makes available to patients prescription medicines without a valid patient-physician relationship or in violation of existing federal or state laws or regulations. The patient-physician relationship is the foundation upon which the practices of medicine and pharmacy are based. State boards of medicine and pharmacy are studying the application of this principle to Internet sites and preparing to take action against those sites that disregard its importance or legal bearing.

TYPES OF LEGAL INTERNET PHARMACY PRACTICE SITES

The legal Internet sites have been so designated because the practices we've documented them to be engaged in are not in direct violation of any existing state or federal laws. The operations are primarily involved in the legitimate dispensing of prescription medications or information. For the purposes of this report, the legal Internet sites are subdivided into seven categories. Although many of the sites are not in complete compliance with all laws at this time, their basic organizational structure is not inherently illegal as in the case of those sites designated "illegal." There is also no way to verify that individual sites within these categories are legitimate or appropriately licensed without an independent verification like NABP's VIPPS program. Consumers using these sites still run the risk of fraud or harm because of the lack of this independent verification.

Information Sites

Among the legal sites, the most commonly found are sites offering information and referrals to other sites. Although these sites are frequently built and maintained by credible organizations, there is no way to ascertain whether the information posted or made available to the public is accurate or simply promotional material or product advertisements. The most questionable sites in this category are those sites that sell or promote herbals, homeopathic, and other alternative therapies. Few, if any, standards exist in these areas to evaluate safe and effective patient care. This is an area of increasing import, since a primary reason people surf the Net is for health care information.

Information sites generally offer static information on over-the- counter, prescription drugs, or alternative therapies. They are hosted by a variety of sponsors: Academic sponsored Manufacturer sponsored Corporate sponsored Individual sponsored (a health care professional)

Over-the-Counter (OTC) Reference Sites Sites in this category offer patient specific recommendations via e- mail regarding the selection and use of OTC medications. The evaluation is conducted principally through an online questionnaire.

Alternative Medicine Sites

Sites in this category offer herbals, vitamins, homeopathics and other nutraceuticals for sale. There is no requirement for a patient- prescriber relationship or a need to complete a cyber questionnaire to complete. The products offered comprise the myriad of offerings currently available in the United States and throughout the world. Some of the products contain controlled substances or prescription medications but are beyond the regulation of state boards of pharmacy because of their classification as dietary supplements.

Pharmacy Sites

The sites that most closely resemble the traditional "brick and mortar" pharmacies are found in this category. These sites offer prescription medications in states where licensed or allowed by law, and when an original written prescription is provided or a verbal order, faxed prescription, or approved electronic prescription is obtained directly from the legally authorized prescriber with a valid patient-prescriber relationship. These are the type of sites most often referred to as the new practice of pharmacy. The,,' offer price shopping, reliable medical information and convenience to the elderly, home hound and those living in rural areas. The sites in this area are the most qualified to apply for and receive certification through NABP's Verified Internet Pharmacy Practice Sites (VIPPS) program.

Transmission or Relay Sites

The sites in this category offer to relay a prescription request to an appropriately licensed pharmacy. The pharmacy obtains a valid prescription from the prescriber. These sites are not engaged in the practices of medicine or pharmacy and would not necessarily be directly regulated by the state boards of pharmacy or medicine. However, they would be required to adhere to confidentiality and security requirements for medical information and patient data. Though a relatively small number of these sites now exist, they may be the easiest and most practical way for private community drugstores to venture onto the Web.

Wholesaler Sites

These sites are assumed to be appropriately licensed wholesalers, offering prescription drugs to what is assumed to be appropriately licensed dispensing facilities. Though few in number, these sites represent the business-to-business aspect of pharmacy practice on the Web.Veterinary Sites These are sites that are assumed to be appropriately licensed veterinary pharmacies offering medications when an original written prescription is provided or a verbal order, faxed prescription, or approved electronic prescription is obtained directly from a licensed veterinarian.

TYPES OF ILLEGAL INTERNET PHARMACY PRACTICE SITES

Illegal pharmacy activities grab the headlines and the moral consciousness of the general public and the media. Though a novice can easily find sites offering lifestyle enhancement drugs and many are annoyed by spam mail pushing these products, few legitimate pharmacies online offer a variety of prescription drugs for the treatment of disease without a prescription. A few unscrupulous companies in our experience operate the majority of sites engaged in this illegal activity.

Prescription Optional

Sites in this category function on the premise that a consumer does not necessarily have to provide a legitimate prescription in order to receive drugs. These sites offer a variety of drugs and provide suggestions for avoiding attention or obtaining prescription medications through existing loopholes in federal or state laws. There is no way to determine whether the drugs being shipped from these sites or their distributors are legitimate since the distribution system is not documented and void of the safeguards presently in place with the FDA and state regulatory agencies. In some cases a prescriber or special interest group, in the belief that the sites can provide legitimate medications at a lower cost, refers patients to these sites.

Questionnaire Sites

Sites in this category provide drugs based upon an online medical history questionnaire. The basic operation of these sites challenge the definition of the physician-patient relationship and seek to compromise the present standards of care advocated by the Federation of State Medical Boards (FSMB) and AMA (Attachment B). They resort to the egregious act of using a questionnaire to replace the patient- physician relationship and engage in related questionable activities such as: Operating the questionnaire so the "correct" answers are provided as defaults Distributing drugs from an unlicensed pharmacy or fraudulent pharmacy operation and Utilizing a prescriber that may not be licensed to treat that patient

Cyberspace Consultations Sites within this category provide prescription medicines via an online cyberspace interaction with the site's personal prescriber. An online medical history questionnaire is usually the only patient contact with the prescriber. The review of the patient's medical history at these sites at a minimum is suspect and in the worst case scenario, non-existent. At these sites, the prescriber is not identified and there is little information concerning the source of the medications or the pharmacy involved. There is no evidence that the prescriber and/or pharmacy/distributor are licensed to practice medicine or pharmacy.

Prescriber-based Sites

Sites of this genre provide prescription medications through a physician as part of his/her practice based on an online medical history questionnaire or electronic interaction with the patient that does not appear to satisfy the standards for a bonafide patient- physician relationship. Although the prescriber is usually identified, there is no indication that he or she is properly licensed to treat the patient. Some of these sites have been linked to spam promotions and other online, unwanted solicitations.

Referral Sites

Sites operating in this manner offer a referral fee to individuals (lay or professional) to use their Web site to solicit and refer prospective buyers of prescription medications to an illegal site.

NABP/FDA PARTNERSHIP AGREEMENT

One of the more important advances in combating the threat of illegal and dangerous Internet sites offering drugs to U.S. consumers has been the partnership agreement executed by NABP, the FDA, and FSMB (Attachment C). The partnership agreement affirms the long-standing cooperative relationship between the states and the FDA and recognizes the respective authority of each. The partnership agreement formalizes the FDA's intent to work with the states to ensure that state authorities are supported in their efforts to act against illegal Internet sites and if the state defers action to the FDA or the threat to the public health is so severe as to necessitate immediate action by the FDA for states to similarly support these initiatives.

NABP's role in this agreement is to serve as a communication liaison between the states and FDA. We are also committed to working with the states to ensure that action is taken when the public health is endangered or state and federal laws are being violated. The Partnership Agreement is another example of agreements or memorandums of understanding that have been executed with the FDA and other federal agencies to maximize existing resources and provide an effective and far-reaching safety net for the public.

CHANGES IN ILLEGAL SITES

In our collaboration with state and federal agencies, distinct changes in the character and number of illegal sites have been observed. The legal actions taken by state and federal agencies have resulted in both domestic and international pharmacies closing their sites. Others are under court orders to post notices to customers that their practice is limited to certain jurisdictions. Some legitimate pharmacies that enter the Internet with illegal intent have returned to the legal practice of pharmacy and revised their sites due to the actions taken by state and federal regulators. Many of the first sites to offer drugs without a prescription or through online prescribing services have dropped prescription drugs from their inventory in favor of herbal and alternative therapies or even Web site development services.

Of the illegal sites that remain, some have become more deviant now providing direct links to pornographic sites. Others have attempted to improve the appearance of their Web sites to present a professional and trustworthy appearance. These later pose a more serious threat to the elderly searching for sources of inexpensive medications. Here again NABP's VIPPS program provides a valuable consumer service. The purpose and goal of the VIPPS program is to provide the public with a means to identify those sites that are legitimate and prepared for the challenges of pharmacy practice. The VIPPS Seal assures consumers that their interaction with that site will provide the level of care required by state laws and regulations.

NABP'S VIPPS PROGRAM

NABP's VIPPS program combines the mandatory requirements of state regulation with specially designed Internet practice criteria developed by an expert panel of state and federal regulators, consumers, providers, and practitioners. An Internet pharmacy earning NABP's VIPPS seal must meet and demonstrate compliance with all mandatory licensure, statutory, and regulatory requirements of the pharmacy practice acts in the states in which they are practicing pharmacy. This compliance is evaluated with a thorough application and review process, independent verification of licensure and disciplinary action through NABP's Disciplinary Clearinghouse Database, and on-site inspection of facilities, personnel, and procedures. Detailed information about the VIPPS program is attached to this report for the Committee's reference, see Attachment A.

One of the questions often raised about the VIPPS program is whether or not there is sufficient security to prevent duplication of the VIPPS Seal by sites who have not earned this certification. The following information summarizes the security provisions built into the VIPPS seal to protect against hackers and fraudulent duplication: The Seal is designed as one integrated graphic and created in an oval and 3-D format using three different graphic programs. It would take an above average program and artist to create a counterfeit or modify a copied Seal. The Seal is trademarked and has been legally defended. Integrated into the Seal, the pop-up flag and the by-line of the programs promotional materials is the real significance of the Seal "Look for the Seal. Click to Verify." The Sears hyperlink transfers the consumer to a dedicated VIPPS verification Web site, not the same VIPPS site as consumers and professionals reach when visiting the NABP Web site. This VIPPS verification site is only linked by the hyperlink on the Seal and is not registered on any search engines. The computer that services the VIPPS verification Web site captures the URL Internet address from the Seal, which establishes where the Seal is currently located.

The VIPPS verification computer then looks up the pharmacy's information on the database using that URL. If the URL where the seal is located does not match the URL in the database

A message is displayed to the consumer that the pharmacy is not in the database and may be displaying a fraudulent seal; An alert is sent to the webmaster; and An alert is sent to the VIPPS program director. The database accessed by the VIPPS verification Web site only exits on the Web site.

The actual master database is kept on a computer that is not linked to either the Internet or the Web site database computer. It is located in another facility. The verification data base is periodically refreshed from the master database so fraudulent data hacked onto it would be short lived. The data displayed includes automatic links to the NABP National Disciplinary Clearinghouse database and hyperlinks to each Web site of the state boards of pharmacy for consumer referrals. It would be difficult to create a credible counterfeit VIPPS verification site.

Consumer Awareness of the VIPPS Program

The first VIPPS seals were awarded in August of 1999. Since that time NABP launched an intensive public awareness program to alert consumers of this service. Information about the VIPPS program appeared in print and broadcast media and special bulletins distributed to consumers by federal agencies.

Medicare has begun a program with the goal to reach every Medicare beneficiary and every Medicare provider with a flier warning of the dangers of the Internet and informing them about VIPPS as a safeguard (Attachment D). A flier to educate prescribing health care professionals is being distributed through state boards of medicine, nursing, and pharmacy to every licensee in America (Attachment E).

The total number of consumers reached through these media are as follows:

Broadcast (television and radio) 2,891,889 @ night 146,000,000 @ week

Magazines 57,933,646 Newspapers 14,729,991 Professional Publications 3,832,777 Public Relations Programs 30,000,000

The VIPPS Seal and Web site activity also provides an indication of consumer interest in and use of the VIPPS program. The following data reflects all of calendar year 1999. Please note that the VIPPS Web site was not opened until June of that year and the first Seals did not appear on the certified online pharmacies until late September.

Consumers entering the VIPPS Web site 21,699 user sessions

Consumers viewing the list of VIPPS certified pharmacies 3,216 user sessions

Consumers clicking on the Seal on a VIPPS pharmacy site 34,735 user sessions

Consumers searching the database for a VIPPS pharmacy 1,418 user sessions

Consumers using VIPPS site to report a suspicious site 108 user sessions UPDATE ON THE VIPPS PROGRAM

There is broad-based bipartisan support and use of VIPPS by consumers, the pharmacy and medical professions, third party payers, state and federal agencies, and foreign government. To date, 329 VIPPS Applications have been downloaded from the NABP Web site. The number of applications to be filed with NABP or under preparation for submission to NABP number several hundred. The following chart lists the activity for submitted applications and awarded seals: (NOTE: CHART NOT TRANSMITTABLE)

STATE AND FEDERAL ACTIONS

Enforcement of existing state laws and regulations is having an increasing effect on illegal sites and their operations. A coalition of governmental agencies is involved in the investigation and prosecution of Internet sites operating illegally in the United States. Much of the activity is occurring both at the state level and through the FDA. On the front line, individual state agencies have taken the initiative in pursuing and prosecuting the entity (pharmacy or distributor) as well as the practitioner (pharmacist or prescriber). State attorneys general have prosecuted online pharmacies and online prescribers for violating the following provisions or professional practice and consumer fraud acts: Unauthorized/unlicensed practice of pharmacy or medicine; Unethical/unprofessional practice of medicine based upon the prescribing of medication without performing a concomitant in-person physical examination; Drug trafficking and the illegal sales of prescription drugs; Solicitation to manufacture a controlled substance; and False/deceptive advertising for failing to disclose to consumers that the pharmacy/physicians were not licensed/registered to do business in the state.

A more comprehensive listing of state actions is found in Attachment G.

The FDA has also taken an active role in issuing a number of "cyber" letters of compliance.

2000 (1990) Product/Description Company Division Released Posted March Online Pharmacy.Co Site: Codcomol Albany Street Pharmacy

February Anagen Web Site: Viagra. Xenical. and Propecia DMC di Vezzi Robertot

Lifestyle Pharmacy Web Site: Various Drug Products Lifestyle Pharmacy

Pharmcom Web Site: Viagra. Propecia. and Xenical Hampstead Trust

United Pharmacy Web Sites: Various Drug Products INK Electronic Media, Ltd.

January Concept Shopping Web Site: Viagra. Xenical. and Propecia Concept Shopping Limited

Elina Pharmaceuticals Web Site: Viagra and Xenical Elina Pharmaceuticals

Menscare Web Site: Viagra Menscare Services

Mens Pharmacy Web Site: Viagra and Propecia Mens Pharmacy c/o Ink Electronic Media, Ltd.

Minitraders Web Site: Viagra. Meridia. and Propecia Minitraders

Pharmacy-Geoff Web Site: Xenical and Propecia Ink Electronic Media, Ltd.

Viagra Go Go Web Site: Viagra Hamada Dayateknindo

Viagra.nu Web Site:Viagra Global Medica

World Pharmacy Web Site: Viagra World Pharmacy, Inc.

The number of state and federal actions is significant. It represents a dramatic turnaround time from when these agencies first discovered what illegal activities were occurring and subsequent disciplinary actions. Some critics maintain that the federal and state agencieshave not acted quickly enough or have not imposed more severe disciplinary actions. These critics fail to recognize that in all instances involving a licensed/registered pharmacy, pharmacist, or prescriber due process must be followed. States cannot arbitrarily revoke a license or registration without the benefit of a hearing or other administrative procedure. Such activities require extensive investigation, preparation. and time. In consideration of all of these factors, NABP maintains that the actions of the states and FDA are timely and effective.

FUTURE INITIATIVES AND RECOMMENDATIONS

State Regulation of U.S.-Based Internet Sites The state boards of pharmacy are adamant in their opposition to any federal preemption of the authority of the states to regulate the practice of pharmacy. The problems with U.S.-based pharmacies and pharmacists can be addressed through a coordinated effort of the states and the Food and Drug Administration. The precedent for such partnerships exists and is best exemplified by the development and implementation of the Prescription Drug Marketing Act of 1987 (PDMA). The PDMA enacted certain provisions and standards at both the state and federal levels that coordinated state and federal activities through the FDA and state boards of pharmacy.

NABP supports this type of cooperative effort and reiterates its request for additional resources for the states to combat the illegal activities of Internet sites such as funding for additional investigators and access to informational databases maintained by federal agencies monitoring and investigating this area.

Continued coordination with the FDA and other federal agencies

NABP and the state boards of pharmacy are open to discussions that would partner the states and NABP with the FDA and other federal agencies provided such partnerships do not preempt state authority to regulate the practice of pharmacy. Together the FDA and states represent an effective regulatory framework to protect U.S. consumers. The Partnership Agreement, which NABP executed with the FDA, is the first step towards increasing our collective efforts and maximizing the resources available to the states and FDA to manage this and other related issues.

Continued Growth of the VIPPS Program

The support from consumers, practitioners, regulators, and the industry for the VIPPS program encourages us. The number of applications submitted to NABP increases every day and the number of sites approved is moving forward at a comfortable and steady pace. We anticipate that the number of seals awarded by the end of the first six months of 2000 will number more than a dozen and the number of pharmacies represented by those seals will exceed 10,000. In light of the fact that the states license/register approximately 72,000 brick and mortar pharmacies across the United States, the number of pharmacies operating under the VIPPS program is momentous.

International Agreements

As NABP indicated in its July 30 Testimony to the House Committee on Commerce Subcommittee on Oversight and Investigations, the most egregious sites are foreign-based. In an effort to stem the illegal activities of these operations, we have conducted discussions with pharmacy jurisdictions in Australia, Canada and New Zealand and with representatives of the International Pharmaceutical Federation (FIP), representing pharmacy organizations throughout the world and including liaisons with the World Health Organization (WHO). As a result of these discussions, NABP and New Zealand will soon enter into an agreement to establish a VIPPS Program in New Zealand. This partnership with New Zealand regulatory authorities will create an international partnership that will provide another mechanism to prevent the illegal distribution of prescription drugs into the U.S. from New Zealand. We are also entering final negotiations with New South Wales, Australia for a similar agreement and establishment of the VIPPS program in that state. Our discussions with Canada are in the preliminary stage but have been met with strong interest and support. The consideration of the VIPPS program by the FIP will occur in August of this year and could result in a recommendation to adopt the VIPPS program in member countries of FIP and by the World Health Organization.

CLOSING AND CONTACT FOR ADDITIONAL INFORMATION

The situation regarding the regulation of online pharmacies has changed significantly during the last year. Through the concerted efforts of the state regulatory authorities, state attorneys general, and the FDA, federal and state laws are being steadily and consistently applied. Their combined efforts are causing illegal online pharmacy sites based in the U.S. to cease operations or change their marketing strategy to exclude prescription drug products. Moreover, in its eight months of operation, NABP's VIPPS certification program has provided thousands of consumers with reliable information about those online pharmacies that have earned the VIPPS Seal. Still, there is a great deal of work to be done to assure the safety and comfort of consumers wishing to receive their pharmaceutical care from online pharmacies. The Internet remains a frontier of vast opportunities; opportunities to improve and enrich the lives of countless individuals, and opportunities to take advantage of these same individuals for personal gain. On behalf of the National Association of Boards of Pharmacy, I would like to thank you once again for allowing us to meet with you today. We stand ready to assist you in any way we can as you continue to investigate this important area of health care. If we can be of any further assistance to the Committee, please feel free to call upon us through Carmen Catizone. NABP Executive Director/Secretary.

END

LOAD-DATE: March 23, 2000

Document 12 of 60.


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