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Comparison of Average Sales Prices and Average Manufacturer Prices: Results for the First Quarter 2024

When Congress established average sales price (ASP) as the basis for Medicare Part B drug reimbursement, it also provided a mechanism for monitoring market prices and limiting potentially excessive Medicare payment amounts. Section 1847A(d)(1)-(3) of the Social Security Act mandates that the Office of Inspector General (OIG) compare ASPs with average manufacturer prices (AMPs) and the widely available market price, if any. If OIG finds that the ASP for a drug exceeded the AMP by 5 percent in the two previous quarters or three of the previous four quarters, the Secretary of Health and Human Services may substitute the reimbursement amount with a lower calculated rate. This quarterly memo summarizes the results of OIG's comparison analysis based on ASP and AMP data reported for the first quarter 2024. The memo specifically reports the number of drugs OIG identified that met the criteria for substitution of a lower reimbursement amount.

Announced or Revised Agency Title Component Report Number(s) Expected Issue Date (FY)
November 2023 Centers for Medicare and Medicaid Services Comparison of Average Sales Prices and Average Manufacturer Prices: Results for the First Quarter 2024 Office of Evaluation and Inspections OEI-03-24-00070 2024