The OIG has released its latest report comparing Part B drug average sales prices (ASP) and average manufacturer prices, this one comparing first quarter 2012 ASPs and AMPs and their impact on Medicare reimbursement for the third quarter of 2012. By way of background, the Social Security Act requires the OIG to notify the HHS Secretary if the ASP for a particular drug exceeds the drug's AMP or widely available market price (WAMP) by a threshold, currently set at 5%. If that threshold is met, the Secretary is authorized to disregard the drug’s ASP and substitute the lesser of the WAMP or 103% of AMP. CMS’s 2012 Medicare physician fee schedule (MPFS) rule specified the circumstances under which AMP-based price substitutions could occur beginning January 2012 (although CMS has not announced any such substitutions to date), and the final 2013 MPFS updated this policy. According to the recent OIG report, ASPs for 28 drug codes exceeded AMPs by at least 5% in the first quarter of 2012, of which 22 had complete AMP data. If reimbursement for these 22 codes had been based on 103% of AMPs in the third quarter of 2012, Medicare would have saved an estimated $739,000 in that quarter.