Comparison of Average Sales and Prices and Average Manufacturer Prices: An Overview of 2009

摘要

By law, OIG must compare ASPs with AMPs. As generally defined in statute, an ASP is a manufacturers sales of a drug to all purchasers in the United States in a calendar quarter divided by the total number of units of the drug sold by the manufacturer in that same quarter, net of any price concessions. Generally, manufacturers must provide the Centers for Medicare & Medicaid Services (CMS) with the ASP for each of their national drug codes (NDC) on a quarterly basis. For most Part B prescription drug Healthcare Common Procedure Coding System (HCPCS) codes, the Medicare reimbursement is equal to 106 percent of the volume-weighted ASPs for the associated NDCs. During 2009, the AMP was generally defined as the average price paid to the manufacturer for the drug in the United States by wholesalers for drugs distributed to the retail pharmacy class of trade. Manufacturers that participate in the Medicaid drug rebate program must provide CMS with the AMP for each of their NDCs on a quarterly basis, with certain exceptions. The objective of this report is to (1) To identify drugs with average sales prices (ASP) that exceeded average manufacturer prices (AMP) by at least 5 percent in any quarter of 2009 and (2) To examine the impact of missing and unavailable AMP data on the Office of Inspector Generals (OIG) pricing comparisons in 2009.