The Food Marketing Institute (FMI) respectfully submits the following comments in response to the interim final rule CMS—4063—IFC (“the rule”) that has been issued by the Centers for Medicare and Medicaid services (CMS) to implement the Medicare Prescription Drug Discount Card Program as authorized by the Medicare Prescription Drug Improvement and Modernization Act of 2003 (MPDIMA). 68 Fed. Reg. 69840 (Dec. 15, 2003).

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