Comparison of Average Sales Prices and Average Manufacturer Prices: Results for the First Quarter of 2026
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 OIG compare ASPs with average manufacturer prices (AMPs) and widely available market prices (WAMPs) (if any). If OIG finds that the ASP for a drug exceeds 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 of 2026. 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) |
|---|---|---|---|---|---|
| October 2025 | CMS | Comparison of Average Sales Prices and Average Manufacturer Prices: Results for the First Quarter of 2026 | Office of Evaluation and Inspections | OEI-03-26-00060 | 2026 |