The OIG has issued its 23rd report comparing average sales prices (ASPs) to average manufacturer prices (AMPs) for Medicare Part B drugs. The latest report identifies 35 drug codes with ASPs that exceeded AMPs by at least 5% in the first quarter of 2011. Of these, 15 had AMP data for every drug product CMS used to establish rates. If reimbursement for these 15 codes had been based on 103% of the AMPs during the third quarter of 2011, as is authorized by law, the OIG estimates that Medicare spending would have been $788,000 lower in that quarter. The OIG could not compare ASPs and AMPs for another 51 HCPCS codes because AMP data were not submitted for any of the products CMS used to calculate payment, although manufacturers for 9% of the drugs had Medicaid drug rebate agreements, which require submission of AMPs. The OIG once again recommends that CMS develop a price substitution policy and lower reimbursement for drugs that exceed the 5% threshold. While CMS has not yet made changes to Part B drug reimbursement as a result of these studies, CMS’s proposed 2012 Medicare physician fee schedule rule would specify the circumstances under which AMP-based price substitutions would occur, beginning in the first quarter of 2012. Under CMS's proposal, reimbursement for 7 of the 15 drugs would have been reduced, saving an estimated $654,000 (CMS's proposed price substitution policy would not apply to codes with partial AMP data).