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Update: Average Sales Price Reporting for Skin Substitutes

Announced on  | Last Modified on  | Project Number: OEI-BL-24-00420
Status
Active
Agency
Centers for Medicare and Medicaid Services

OBJECTIVE

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.

TIMELINE

  • November 15, 2024
    Announced
  • Today
    Office of Evaluation and Inspections In-Progress
  • Est FY2026
    Estimated Fiscal Year for Project Completion
Work Plan Type
Office of Evaluation and Inspections
HHS Agencies
Centers for Medicare and Medicaid Services
Issue Areas
Financial Stewardship Prescription Drug
Target Groups
Elderly
Financial Groups
Medicare B