The OIG has released another report comparing Medicare average sales prices (ASPs) for Part B drugs with AMPs, this one summarizing data from 2010. The OIG identified 32 drug Healthcare Common Procedure Coding System (HCPCS) codes with complete AMP data for which the ASP exceeded the AMP by at least 5% in one or more quarters of 2010. If reimbursement for these codes had been lowered to 103% of the AMPs for the applicable quarters (as is authorized by the statute), Medicare spending would have been reduced by approximately $13.2 million from the third quarter of 2010 through the second quarter of 2011. The OIG excluded at least 9% of HCPCS codes from its comparisons because AMPs were missing or unavailable for all of the associated drug products. While CMS has made no price adjustments to date as a result of 24 OIG reports comparing ASP and AMPs, the OIG cites CMS’s proposed physician fee schedule rule (which subsequently was adopted) that specifies the circumstances under which AMP-based price substitutions would occur. Under the final rule, CMS will apply its AMP substitution policy only when the ASP exceeds the AMP by 5% in two consecutive quarters immediately prior to the current pricing quarter, or three of the previous four quarters immediately prior to the current quarter, and only when AMP and ASP comparisons are based on the same set of NDCs for a billing code. According to the OIG, if CMS’s proposed price substitution policy had been in effect during 2010, reimbursement for 10 of the 32 HCPCS codes with complete AMP data would have been lowered to 103% of the AMPs, saving an estimated $2.3 million. CMS did not concur with an OIG recommendation to seek legislation requiring all manufacturers of Part B-covered drugs to submit both ASPs and AMPs, and CMS did not address an OIG recommendation to use its price substitution policy when only partial AMP data is available.