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Editor's Note: The following statement is being published at the request of the Public Citizen's Health Research Group, the Public Citizen's Citizen A...

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Editor's Note: The following statement is being published at the request of the Public Citizen's Health Research Group, the Public Citizen's Citizen Action Group and

The Center for the Study· of Responsive Law, in response to APhA's Formal Comment to the Federal Trade Commission on Prescription Price Disclosure as published

in the APhA Journal, Vol. NS 15, pp. 668-677,December 1975.

U-ubltc Citizen Public Citizen's Health Research Group, the Citizen Action Group and Ralph Nader's Center for the Study of Responsive Law fully support the FTC action on prescription price disclosure. The American Pharmaceutical Association (APhA) erroneously reported on November 21, 1975, that these groups oppose prescription dru g price advertising. These groups believe that effective price competition wi ll help lower prescription drug prices where prices are excessive and that price competition is currently hindered by the difficulty consumers have in getting price information. These groups believe that state legislatures and pharmacy boards have prohibited prescription drug price advertsiing in order to protect small pharmacies and that s uch protection is not warranted. The consumer will pay the sometimes-higher price at small pharmacies if the extra cost is demonstrably worth extra services performed, but such a judgement can be made only if comparative prices are known. The groups named above oppose the APhA viewpoint with regard to prescription drug advertising. Their 35 page r ep ort to the FTC on prescription drug price disclosure contains ten recommendations including these two intended to support the advertising of prescription drug prices : "1)

to the dissemination of informarices at the retail level must

A11

tion re be revo

"10) Media advertising cannot be made mandatory. Although existing barriers to advertising must be removed, concurrently strict regulations must be instituted in an attempt to eliminate any fraudulent or misleading advertising practices that may ensue." Our report to the FTC contained both positive and negative comments about all types of prescription drug price disclosures. The intention of the report was a clear endorsement of the FTC program, which is consistent with the views these groups have held and expressed for some time. Public Citizen's Health Research Group Public Citizen's Citizen Action Group The Center for the Study of Responsive Law

H EALTH R ESEARCH GROUP. 2000 P STREET, N.W., WASHINGTON, D .C. 20036 • (202) 872-0320

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Journal of the American Pharmaceutical Association