OIG Compares Second Quarter 2010 ASPs & AMPs
A new OIG report compares second-quarter 2010 average sales prices (ASP) and average manufacturer prices (AMP) and their impact on Medicare reimbursement for the fourth quarter of 2010. According to the OIG, there were 25 HCPCS codes with ASP that exceeded AMP by at least 5% in the second quarter of 2010. Of these codes, 10 had complete AMP data (i.e., AMP data for every drug product CMS used to set reimbursement). If reimbursement for all 10 codes with complete AMP data had been based on 103% percent of AMP during the fourth quarter of 2010 (as is authorized by the statute), Medicare expenditures would have been reduced by about $713,000 in that quarter. The OIG could not compare ASPs and AMPs for 69 additional HCPCS codes because AMP data were not submitted for any or all of the drug products. The OIG observes that 16% of the manufacturers that did not submit AMP data for any codes had Medicaid drug rebate agreements under which they generally were required to submit AMPs. The OIG states that it will continue to work with CMS to pursue appropriate actions against manufacturers that fail to submit required pricing data.
