Why OIG Did This Review. To address concerns about the accuracy of average sales prices (ASPs) for Medicare Part B drugs, Congress included a provision in the Consolidated Appropriations Act, 2021, that directs the Office of Inspector General (OIG) to review the accuracy of manufacturer-reported ASP data. Ensuring the accuracy of ASPs is vital because the Centers for Medicare & Medicaid Services (CMS) uses these prices to directly calculate payment amounts under Medicare Part B. How OIG Did This Review. OIG has previously conducted several resource-intensive audits of manufacturer-reported pricing data that resulted in limited findings. In general, OIG’s ability to identify noncompliance in price reporting is limited because of broad regulations that allow manufacturers to make reasonable assumptions in the absence of specific guidance. For this reason, OIG decided to try a different approach to assess the accuracy of ASPs. For this evaluation, we compared ASPs for the 30 highest-expenditure drugs in Medicare Part B to different benchmark prices for prescription drugs in the second quarter of 2021. We then surveyed the 20 manufacturers of these 30 drugs to determine what factors they take into consideration when calculating their ASPs. The 30 drugs in our review accounted for nearly 64 percent of Medicare Part B drug spending in 2020. The entire body of drugs marketed by the 20 manufacturers included in our survey accounted for almost 80 percent of Part B drug spending.
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