Update: Average Sales Price Reporting for Skin Substitutes

In March 2023, OIG issued a report that found that manufacturer noncompliance with new average sales price (ASP) reporting requirements for skin substitutes led to millions in excessive Part B payments. ASP is used to set Medicare payment amounts. Since that report was issued, Part B expenditures for skin substitutes have risen significantly, exceeding $1.6 billion in the fourth quarter of 2023 alone. Despite efforts by CMS to address the accuracy and completeness of ASP reporting, the sharp increase in expenditures raises concerns that poor ASP reporting continues to result in excess Medicare payments. Given this rapid increase in Part B expenditures and a recent history of fraud in the area, this study will provide an update on reporting issues as well as highlight billing trends and identify potential solutions to any challenges in using the ASP methodology for skin substitutes.

Announced or Revised	Agency	Title	Component	Report Number(s)	Expected Issue Date (FY)
November 2024	Centers for Medicare and Medicaid Services	Update: Average Sales Price Reporting for Skin Substitutes	Office of Evaluation and Inspections	OEI-BL-24-00420	2025