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to compete on price, such protected industries have often been marked by relative inefficiency, due to their failure to innovate. In such cases, the day of judgment is merely postponed at great cost to the consuming public.

Thus, it has been our experience that the sounder course of public policy is not to attempt to protect existing interests from the forces of socially desirable change by creating exemptions from the antitrust laws. Rather it is better to attempt to devise systems which meet the changing needs of the public in a manner which promotes efficiency while allowing all producers a fair opportunity to compete on the basis of their ability to satisfy consumer demands.

I do not wish this statement to be misunderstood. Small businessmen, such as the independent druggists, are capable of making important contributions to the public interest. To the extent that prepaid prescription plans become a significant factor in the provision of health services, it behooves us to try to make sure that the plans do not impose burdens which adversely affect the fortunes of the independent druggist for reasons unrelated to efficiency. Programs designed by large entities can impose burdens that are tolerable, if inconvenient, for large suppliers, but intolerable for smaller suppliers. Prepaid prescription drug plans should, therefore, be designed to provide for prompt reimbursement to participating druggists with a minimum of administrative burden. Such plans can best meet the goals of our nation if they are administered efficiently and with respect for the legitimate interests and needs of all those groups participating in the plan.

In conclusion, it appears to us that prepaid prescription drug plans may represent the beginning of a significant change in one aspect of this nation's health care system. At the present time, however, it is too early to make any prediction as to the manner in which these type of plans will eventually evolve or how significant they will become on a national basis. In view of their potential importance and the economic and social issues that they raise, we believe that a careful study of the problems should be undertaken prior to the enactment of new legislation. While various aspects of these plans have been studied by some of the interests involved, we believe that there is a need for a more comprehensive review. Such a study could be undertaken by a Task Force on which both the public agencies and interested private groups could be represented. Naturally, the Department of Justice would stand ready to provide such a Task Force with advice on any antitrust questions that might arise.

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EXHIBIT D TO STATEMENT OF M. WILLIAM WILSON 1

PREPAID PRESCRIPTION PROGRAM REIMBURSEMENT FORMS

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1 Mr. M. William Wilson's statement appears at p. 41, exhibits A-C appear at pp. 47, 48.

PRESCRIPTION DRUG PROGRAM

FOR CERTAIN EUG BLE runy MOTOR COMPANY ESIPLUTECS AND THEIR DEPENDENTS

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Drugs covered: Legend drugs; compounds W/A legend; non-injectables 1; injectable insulin.

Drugs not covered: Contraceptives, whether prescribed for contraception or not; Rx's whose usual retail is $2 and under.

Generics: When written for, use lowest cost drug in stock.

Maximum quantities: 34-day supply, except for 100's in nitroglycerin and thyroid.

Refills: Up to 1 year.

Number Rx's per claim form: One.

ID card: Cardboard.

Dependents covered: ID card says if dependents covered or not.

Co-pay: $2, stated on I.D. card.

Professional fee: $2.05.

Acquisition cost: Rolodex.

Insulin: Acquisition cost plus dispensing fee or "usual charge" (lowest).2

State tax: Tax not charged, is included in professional fee.

Imprinter: None.

Drug identification on claim: Write drug name; print or type claim.

Claim distribution: All copies to G.O. accounting.

When forwarded: End of each week with sales and cash report.

Reorder claim forms from: Mr. I. Kaplan, Starcraft Drugs, 159 E. Main Street, Cincinnati, OH 45202.

1 Non-injectables covered: Adrenalin, acidatate, aveeno, acetaminophen NF.

2 In all states with tax on insulin, tax is added to acquisition cost when "usual charge" is used. If professional fee is used, tax is in fee.

Who Is Covered By This Program?

It covers employees of corporations, companies and organizations whose group health insurance is provided by Ætna. In most cases the employee's family is covered, too. In a few years this plan should cover several million people from coast to coast.

Persons insured under the program will present a special Etna identification card to you when asking for a prescription. The card will not only identify the employee, but will indicate whether dependents are eligible for benefits, the extent of coverage and the deductible amount, if any.

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