1. “Draft OIG Compliance Program Guidance for Pharmaceutical Manufacturers,”;Federal Register,2002
2. 46. ACCME, “Standards for Commercial Support,” available at (last visited September 6, 2011).
3. “Compliance Program Guidance,”;Federal Register,2003
4. 34. Petersen, M. , “Vermont to Require Drug Makers to Disclose Payments to Doctors,” New York Times, June 13, 2002, at 1.