Department of Health and Human Services
OFFICE OF 
   
INSPECTOR GENERAL 
 
 
 
 
 
 
C   A S
OMPARISON OF  VERAGE  ALES 
 
P A
R ICES AND  VERAGE 
 
M P : 
ANUFACTURER  RICES
 
 
A O 2007 
N  VERVIEW OF 
 
 
 
 
 
Daniel R. Levinson  
Inspector General 
 
December 2008 
OEI-03-08-00450   
Office of Inspector General 
http://oig.hhs.gov 
 
The mission of the Office of Inspector General (OIG), as mandated by Public Law 95-452, as 
amended, is to protect the integrity of the Department of Health and Human Services 
(HHS) programs, as well as the health and welfare of beneficiaries served by those 
programs.  This statutory mission is carried out through a nationwide network of audits, 
investigations, and inspections conducted by the following operating components: 
Office of Audit Services 
The Office of Audit Services (OAS) provides auditing services for HHS, either by conducting 
audits with its own audit resources or by overseeing audit work done by others.  Audits 
examine the performance of HHS programs and/or its grantees and contractors in carrying 
out their respective responsibilities and are intended to provide independent assessments of 
HHS programs and operations.  These assessments help reduce waste, abuse, and 
mismanagement and promote economy and efficiency throughout HHS. 
Office of Evaluation and Inspections 
The Office of Evaluation and Inspections (OEI) conducts national evaluations to provide 
HHS, Congress, and the public with timely, useful, and reliable information on significant 
issues.  These evaluations focus on preventing fraud, waste, or abuse and promoting 
economy, efficiency, and effectiveness of departmental programs.  To promote impact, OEI 
reports also present practical recommendations for improving program operations.  
Office of Investigations 
The Office of Investigations (OI) conducts criminal, civil, and administrative investigations 
of fraud and misconduct related to HHS programs, operations, and beneficiaries.  With 
investigators working in all 50 States and the District of Columbia, OI utilizes its resources 
by actively coordinating with the Department of Justice and other Federal, State, and local 
law enforcement authorities.  The investigative efforts of OI often lead to criminal 
convictions, administrative sanctions, and/or civil monetary penalties. 
Office of Counsel to the Inspector General 
The Office of Counsel to the Inspector General (OCIG) provides general legal services to 
OIG, rendering advice and opinions on HHS programs and operations and providing all 
legal support for OIGs internal operations.  OCIG represents OIG in all civil and 
administrative fraud and abuse cases involving HHS programs, including False Claims Act, 
program exclusion, and civil monetary penalty cases.  In connection with these cases, OCIG 
also negotiates and monitors corporate integrity agreements.  OCIG renders advisory 
opinions, issues compliance program guidance, publishes fraud alerts, and provides other 
guidance to the health care industry concerning the anti-kickback statute and other OIG 
enforcement authorities.   
 
   
E X E C U T I V E   S U M M A R Y  
 E X E C U T I V E   S U M M A R Y  
OBJECTIVE
 
1.  To identify drugs with average sales prices (ASP) that would have 
exceeded average manufacturer prices (AMP) by at least 5 percent 
in any quarter of 2007 if the revised ASP payment methodology had 
been in effect during the entire year. 
2.  To examine the impact of missing or unavailable AMP data on 
mandated comparisons between ASPs and AMPs in 2007. 
BACKGROUND 
Since January 2005, Medicare Part B has been paying for most covered 
drugs using a reimbursement methodology based on ASPs.  In general 
terms, an ASP is a manufacturers sales of a drug to all purchasers in 
the United States in a calendar quarter divided by the total number of 
units of the drug sold by the manufacturer in that same quarter, net of 
any price concessions.  Manufacturers report ASPs by national drug 
codes (NDC) and must provide the Centers for Medicare & Medicaid 
Services (CMS) with the ASP and volume of sales for each of their NDCs 
on a quarterly basis.  Under the ASP reimbursement methodology, 
Medicares allowance for most Part B drug codes is equal to 106 percent 
of the volume-weighted ASPs for the drugs NDCs.  
By law, the Office of Inspector General (OIG) must compare ASPs with 
AMPs.  As generally defined in statute, the AMP is the average price 
paid to the manufacturer for the drug in the United States by 
wholesalers for drugs distributed to the retail pharmacy class of trade.  
Manufacturers whose drugs are covered by Medicaid must provide CMS 
with the AMP for each of their NDCs on a quarterly basis as part of the 
Medicaid drug rebate program.   
If OIG finds that the ASP for a drug exceeds the AMP by a certain 
percentage (currently 5 percent), the Secretary of the Department of 
Health and Human Services (the Secretary) may disregard the ASP for 
the drug when setting reimbursement and shall substitute the payment 
amount with the lesser of either the widely available market price or 
103 percent of the AMP.   
To date, OIG has issued seven quarterly reports comparing ASPs to 
AMPs.  This current pricing comparison examines data throughout all 
four quarters of 2007 using a revised ASP payment methodology 
recently implemented by statute.  In December 2007, the Medicare, 
  OEI-03-08-00450  COMPARISON OF ASPS AND AMPS: AN OVERVIEW OF 2007  i   
 
   
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Medicaid, and SCHIP Extension Act of 2007, P.L. No. 110-173, changed 
the way in which CMS calculates volume-weighted ASPs, effective  
April 1, 2008.     
For this study, we obtained ASP and AMP data submitted by 
manufacturers for the first through fourth quarters of 2007.  We 
calculated a volume-weighted ASP and AMP for each drug in each 
quarter using CMSs revised ASP payment methodology.  We compared 
ASPs and AMPs for each quarter in 2007 and identified drug codes that 
would have met the 5-percent threshold if the revised payment 
methodology had been in effect throughout the year. 
In addition, we identified the number of NDCs for which AMP data 
were missing or unavailable in 2007, as well as the number of drug 
codes that were removed from OIGs pricing comparisons because AMPs 
were missing or unavailable.  For the purposes of this study, an AMP 
was considered missing if the manufacturer had a Medicaid rebate 
agreement in 2007 but did not submit a price for one or more quarters 
or unavailable if the manufacturer did not participate in the Medicaid 
drug rebate program and was therefore not required to submit AMP 
data to CMS. 
FINDINGS 
If the revised payment methodology had been in effect throughout 
2007, 71 drug codes would have met the 5-percent threshold in at 
least one quarter.  One-fourth of these drug codes (18 of 71) would have 
met the 5-percent threshold during multiple quarters of 2007.  ASPs for 
three of these drug codes (J1364, J2690, and Q0169) would have exceeded 
the AMPs by at least 5 percent in every quarter of 2007.    
Additional codes may have met the 5-percent threshold in 2007; 
however, missing or unavailable AMPs prevented OIG from 
performing pricing comparisons on these codes.  A total of                     
1,185 NDCs had no AMP data during one or more quarters of 2007.  
Manufacturers for almost half of these drug products participated in the 
Medicaid drug rebate program in 2007 and were therefore generally 
required to submit AMP data for at least certain of their products.  
Because some NDCs had missing or unavailable AMPs, the number of 
pricing comparisons performed in 2007 was reduced by about 25 percent 
in each of the first and third quarters and by over 40 percent in each of 
the second and fourth quarters.  In fact, OIG was unable to perform any 
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pricing comparisons on 106 drug codes in 2007 because of missing or 
unavailable AMP data.   
RECOMMENDATIONS 
This is OIGs eighth report comparing ASPs to AMPs.  The law directs 
the Secretary to lower reimbursement amounts for drugs with ASPs 
that exceed AMPs by at least 5 percent.  Although CMS has 
acknowledged the Secretarys authority to adjust Part B reimbursement 
amounts based on the findings of OIGs pricing comparisons, the agency 
has yet to make any changes as a result of these studies.   
Missing or unavailable AMP data have prevented OIG from performing 
mandated pricing comparisons on some drug codes.  Drug 
manufacturers that fail to provide required AMPs in a timely manner 
may be subject to administrative action, including civil monetary 
penalties.   
Consistent with statutory requirements, we recommend that CMS:  
Develop a process to adjust payment amounts based on the results 
of OIGs pricing comparisons.                                                                               
Subsequently lower Medicare reimbursement amounts for drugs with 
ASPs that meet the 5-percent threshold specified in section 
1847A(d)(3) of the Act.                 
Continue to explore and undertake a range of efforts to ensure that 
drug manufacturers are submitting the required AMP data in a timely 
manner, including collaborating with OIG about administrative 
remedies for noncompliance.  
AGENCY COMMENTS AND OFFICE OF INSPECTOR GENERAL 
RESPONSE 
CMS concurred with our recommendation to develop a process for 
adjusting payment amounts based on the results of OIGs pricing 
comparisons.  However, CMS did not specifically concur with our 
recommendation to lower Medicare reimbursement for drugs that meet 
the 5-percent threshold.  Rather, CMS emphasized both the complexity 
of substituting payment amounts and the importance of proceeding 
cautiously as it seeks to understand the appropriate threshold 
percentage for pricing substitutions.  In response to our final 
recommendation, CMS stated that it will continue its efforts to ensure 
that manufacturers are submitting required AMP data in a timely 
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R E C O M M E N D A T I O N S  
manner and that it supports adequate enforcement action against those 
that fail to comply with reporting requirements.   
OIG acknowledges that CMS must make complex decisions regarding 
price substitutions for eligible drugs.  However, consistent with 
statutory requirements, we continue to recommend that Medicare 
reimbursement amounts for eligible codes be lowered pursuant to 
section 1847A(d)(3) of the Act.  OIG will continue to assist CMS, both in 
developing a timely and effective price substitution policy and in taking 
appropriate action against manufacturers that fail to comply with  
AMP-reporting requirements.   
  
  OEI-03-08-00450  COMPARISON OF ASPS AND AMPS: AN OVERVIEW OF 2007  iv   
 T A B L E   O F   C O N T E N T S  
EXECUTIVE SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . i
 
 
I N T RO DUC T IO N . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 
 
 
F I N D IN G S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 
Seventy-one drug codes met the 5-percent threshold in at least             
one quarter of 2007 under the revised payment methodology . . . . 9 
Missing or unavailable AMP data prevented OIG from                     
performing pricing comparisons. . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 
 
 
R E C O MMEN D A T ION S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 
Agency Comments and Office of Inspector General Response . . . 13 
 
 
APPENDIXES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 
  A:  Equations Used by the Centers for Medicare & Medicaid        
Services To Calculate Volume-Weighted Average Sales                   
Prices. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 
  B:  Previous Office of Inspector General Reports Comparing               
Average Sales Prices and Average Manufacturer Prices. . . . . 16 
  C:  Detailed Methodology for Calculating Volume-Weighted                   
Average Sales Prices and Average Manufacturer Prices                  
for 2007 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 
  D:  Seventy-one Healthcare Common Procedure Coding System       
Codes With Average Sales Prices That Exceeded Average 
Manufacturer Prices by at Least 5 Percent in 2007 Under               
the Revised Payment Methodology . . . . . . . . . . . . . . . . . . . . . 19 
  E:  Agency Comments. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 
 
 
A C K NO WL E D G M E N T S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24   
 
   
E X E C U T I V E   S U M M A R Y  
 I N T R O D U C T I O N  
OBJECTIVES 
1.  To identify drugs with average sales prices (ASP) that would have 
exceeded average manufacturer prices (AMP) by at least 5 percent 
in any quarter of 2007 if the revised ASP payment methodology had 
been in effect during the entire year. 
2.  To examine the impact of missing or unavailable AMP data on 
mandated comparisons between ASPs and AMPs in 2007. 
BACKGROUND 
Section 1847A(d)(2)(B) of the Social Security Act (the Act) mandates 
that the Office of Inspector General (OIG) compare ASPs with AMPs.  If 
OIG finds that the ASP for a drug exceeds the AMP by a certain 
percentage (currently 5 percent), section 1847A(d)(3)(A) of the Act states 
that the Secretary of the Department of Health and Human Services 
(the Secretary) may disregard the ASP for the drug when setting 
reimbursement amounts.  Section 1847A(d)(3)(C) of the Act goes on to 
state that  . . . the Inspector General shall inform the Secretary (at 
such times as the Secretary may specify to carry out this subparagraph) 
and the Secretary shall, effective as of the next quarter, substitute for 
the amount of payment . . . the lesser of (i) the widely available market 
price . . . (if any); or (ii) 103 percent of the average manufacturer                 
price . . . .   
To date, OIG has issued seven quarterly comparisons of ASPs and 
AMPs, including one for each quarter of 2007.  This current report 
examines data throughout all four quarters of 2007 using a revised ASP 
payment methodology recently implemented by the Medicare, Medicaid, 
and SCHIP Extension Act of 2007 (Extension Act), P.L. No. 110-173.     
Medicare Part B Coverage of Prescription Drugs 
Medicare Part B covers only a limited number of outpatient prescription 
drugs.  Covered drugs include injectable drugs administered by a 
physician; certain self-administered drugs, such as oral anticancer 
drugs and immunosuppressive drugs; drugs used in conjunction with 
durable medical equipment; and some vaccines.  
Medicare Part B Payments for Prescription Drugs 
The Centers for Medicare & Medicaid Services (CMS) contracts with 
private companies, known as carriers, to process and pay Medicare             
Part B claims, including those for prescription drugs.  To obtain 
reimbursement for covered outpatient prescription drugs, physicians 
  OEI-03-08-00450  COMPARISON OF ASPS AND AMPS: AN OVERVIEW OF 2007  1   
 
   
I N T R O D U C T I O N  
and suppliers submit claims to their carriers using procedure codes.  
CMS established the Healthcare Common Procedure Coding System 
(HCPCS) to provide a standardized coding system for describing the 
specific items and services provided in the delivery of health care.  In 
the case of prescription drugs, each HCPCS code defines the drug name 
and dosage size but does not specify manufacturers or package sizes.   
Medicare and its beneficiaries spent about $11 billion for Part B drugs 
in 2007.1  Although Medicare paid for more than 675 outpatient 
prescription drug HCPCS codes that year, most of the spending for           
Part B drugs was concentrated on a relatively small subset of those 
codes.  In 2007, 55 codes accounted for 90 percent of the expenditures 
for Part B drugs, with only 12 of these drugs representing half of the 
total Part B drug expenditures. 
Reimbursement Methodology for Part B Drugs and Biologicals  
Since January 2005, Medicare Part B has been paying for most covered 
drugs using a reimbursement methodology based on ASPs.2  Section 
1847A(c) of the Act, as added by the Medicare Prescription Drug, 
Improvement, and Modernization Act of 2003, P.L. No. 108-173, defines 
an ASP as a manufacturers sales of a drug to all purchasers in the 
United States in a calendar quarter divided by the total number of units 
of the drug sold by the manufacturer in that same quarter.  The ASP is 
net of any price concessions, such as volume discounts, prompt pay 
discounts, cash discounts, free goods contingent on purchase 
requirements, chargebacks, and rebates other than those obtained 
through the Medicaid drug rebate program.3  Sales that are nominal in 
amount are exempted from the ASP calculation, as are sales excluded                         
from the determination of best price in the Medicaid drug rebate 
program.4 5 
 
1 Figure based on CMSs 2007 Part B Extract and Summary System data, which were                
90 percent complete at the time of extraction (March 2008).   
2 In 2004, the reimbursement amount for most covered drugs was based on 85 percent of 
the average wholesale price as published in national pricing compendia, such as the Red 
Book.  Prior to 2004, Medicare Part B reimbursed for covered drugs based on the lower of 
either the billed amount or 95 percent of the average wholesale price. 
3 Section 1847A(c)(3) of the Act.  
4 Pursuant to section 1927(c)(1)(C)(i) of the Act, best price is the lowest price available 
from the manufacturer during the rebate period to any wholesaler, retailer, provider, health 
maintenance organization, nonprofit entity, or governmental entity within the United 
States, with certain exceptions. 
5 Section 1847A(c)(2) of the Act.  
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I N T R O D U C T I O N  
Manufacturers report ASPs by national drug codes (NDC), which are 
11-digit identifiers that indicate the manufacturer, product dosage form, 
and package size of the drug.  Manufacturers must provide CMS with 
the ASP and volume of sales for each NDC on a quarterly basis, with 
submissions due 30 days after the close of each quarter.6 
Because Medicare Part B reimbursement for outpatient drugs is based 
on HCPCS codes rather than NDCs and more than one NDC may meet 
the definition of a particular HCPCS code, CMS has developed a file 
that crosswalks manufacturers NDCs to HCPCS codes.  CMS uses 
information in this crosswalk to calculate volume-weighted ASPs for 
covered HCPCS codes.   
Calculation of Volume-Weighted Average Sales Prices 
To calculate volume-weighted ASPs, CMS uses an equation that 
involves the following variables:  the ASP for the 11-digit NDC as 
reported by the manufacturer, the volume of sales for the NDC as 
reported by the manufacturer, and the number of billing units in the 
NDC as determined by CMS.  The amount of the drug contained in an 
NDC may differ from the amount of the drug specified by the HCPCS 
code that providers use to bill Medicare.  Therefore, the number of 
billing units in an NDC describes the number of HCPCS code units that 
are in that NDC.  For instance, an NDC may contain a total of                      
10 milliliters of Drug A, but the corresponding HCPCS code may be 
defined as only 5 milliliters of Drug A.  In this case, there are two billing 
units in the NDC.  CMS calculates the number of billing units in each 
NDC when developing its crosswalk files.   
Prior to April 2008, CMS calculated volume-weighted ASPs using the 
equation presented in Appendix A.  However, section 112(a) of the 
Extension Act changed section 1847A(b) of the Act to require that CMS 
compute volume-weighted ASPs using a revised methodology, effective 
April 2008.  This revised methodology was initially proposed by OIG in 
a February 2006 report entitled Calculation of Volume-Weighted 
Average Sales Price for Medicare Part B Prescription Drugs                 
(OEI-03-05-00310).  The revised equation for calculating                        
volume-weighted ASPs is also provided in Appendix A.   
Under the ASP pricing methodology, the Medicare reimbursement for 
most Part B drugs is equal to 106 percent of the volume-weighted ASP 
 
6 Section 1927(b)(3) of the Act.  
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I N T R O D U C T I O N  
for the HCPCS code.7  However, there is a two-quarter lag between the 
sales period for which ASPs are reported and the effective date of the 
reimbursement amounts.  For example, ASPs from the first quarter of 
2007 were used to establish reimbursement amounts for the third 
quarter of 2007, and ASPs from the fourth quarter of 2007 were used to 
establish reimbursement for the second quarter of 2008.       
As a result of this lag period, the methodological changes that went into 
effect in April 2008 were applied to ASP data from two quarters prior, 
i.e., the fourth quarter of 2007.  In other words, CMS used more than 
one methodology to volume-weight ASP data submitted by 
manufacturers for 2007.  The ASP submissions from the first through 
third quarters of 2007 were volume-weighted using the previous ASP 
payment methodology, whereas fourth-quarter ASP submissions were 
volume-weighted using the revised methodology.     
The Medicaid Drug Rebate Program and Average Manufacturer Prices 
For Federal payment to be available for covered outpatient drugs 
provided under Medicaid, sections 1927(a)(1) and (b)(1) of the Act 
mandate that drug manufacturers enter into rebate agreements with 
the Secretary and pay quarterly rebates to State Medicaid agencies.  
Under these rebate agreements and pursuant to section 1927(b)(3) of 
the Act, manufacturers must provide CMS with the AMP for each of 
their NDCs on a quarterly basis, with submissions due 30 days after the 
close of each quarter.8   
As generally defined in section 1927(k)(1) of the Act, the AMP is the 
average price paid to the manufacturer for the drug in the United 
States by wholesalers for drugs distributed to the retail pharmacy class 
of trade.  Prior to the passage of the DRA, manufacturers were required 
to deduct customary prompt pay discounts when calculating AMPs.  
However, section 6001(c)(1) of the DRA amended section 1927(k)(1) of 
the Act, such that AMPs must be determined without regard to 
customary prompt pay discounts, effective January 2007.  In December 
2006, CMS instructed manufacturers to exclude customary prompt pay 
 
7 Medicare beneficiaries are responsible for 20 percent of this amount in the form of 
coinsurance. 
8 Section 6001(b)(1)(A) of the Deficit Reduction Act of 2005 (DRA), P.L. No. 109-171, 
changed section 1927(b) of the Act to require that manufacturers also report AMPs on a 
monthly basis, effective January 2007.  Drug manufacturers will continue to report 
quarterly AMP data in addition to their monthly submissions.  
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I N T R O D U C T I O N  
discounts from their AMP calculations as of January 2007.9  In July 
2007, CMS published a final rule that, among other things, implements 
section 6001(c)(1) of the DRA and clarifies the way in which the AMP 
must be calculated.10  Specifically, 42 CFR  447.504 of the final 
regulation clarifies the manner in which the AMP is to be determined.11 
The AMP is generally calculated as a weighted average of prices for all 
of a manufacturers package sizes of a drug sold during a given quarter 
and is reported for the lowest identifiable quantity of the drug (e.g.,                
1 milligram, 1 milliliter, 1 tablet, 1 capsule).   
If a manufacturer fails to provide AMP data in a timely manner, civil 
monetary penalties may be imposed.12  In addition, pursuant to section 
1927(b)(4)(B) of the Act, the Secretary may terminate a rebate 
agreement for violation of the requirements of the agreement or other 
good cause shown.  CMS has taken actions to terminate manufacturers 
for failure to report drug pricing data as required by section 1927 of the 
Act.  CMS has also provided OIG with information about manufacturers 
that failed to submit drug pricing data for the purposes of evaluating 
potential civil monetary penalty actions.  
Office of Inspector Generals Monitoring of Average Sales Prices and 
Average Manufacturer Prices 
Since the ASP reimbursement methodology for Part B prescription 
drugs was implemented in January 2005, OIG has issued seven reports 
comparing ASPs and AMPs.  A list of the seven previously issued 
reports is provided in Appendix B.   
Four of OIGs seven pricing comparisons used ASP and AMP data from 
2007, with one report issued for each of the quarters in the calendar 
year.13  Reports comparing first through third-quarter ASPs and AMPs 
 
9 Medicaid Drug Rebate Program Bulletin for Participating Drug Manufacturers, Release 
No. 76, December 15, 2006. 
10 72 Fed. Reg. 39142 (July 17, 2007). 
11 In December 2007, the United States District Court for the District of Columbia 
preliminarily enjoined the implementation of the regulation for certain purposes not 
relevant to this report.  Section 203 of the Medicare Improvements for Patients and 
Providers Act of 2008 also delayed the implementation of certain aspects of the regulation 
and the DRA requirements.  Again, those aspects are not relevant for the purposes of this 
report.  
12 Pursuant to section 1927(b)(3)(C) of the Act. 
13 OEI-03-07-00530, September 2007; OEI-03-08-00010, December 2007; OEI-03-08-00130, 
May 2008; and OEI-03-08-00340, August 2008. 
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used CMSs previous method for volume-weighting data.  The report 
comparing fourth-quarter ASPs and AMPs used the revised method for 
volume-weighting data.   
Although CMS has acknowledged the Secretarys authority to adjust 
ASP payment limits based on the findings of OIGs pricing comparisons, 
the agency has yet to make any changes to Part B drug reimbursement 
as a result of these studies.  In commenting on one of OIGs reports, 
CMS expressed a desire to better understand fluctuating differences 
between ASPs and AMPs, with the intent of developing a process to 
adjust payment amounts based on the results of OIGs pricing 
comparisons.14  However, CMS has not specified what, if any, steps it 
will take to adjust Medicare reimbursement amounts for drugs that 
meet the 5-percent threshold specified in section 1847A(d)(3) of the Act. 
This current report is OIGs first annual overview of ASPs and AMPs, 
and it examines data across all four quarters of 2007 using a revised 
ASP payment methodology recently implemented by CMS.     
OIG will continue to issue reports based on quarterly pricing 
comparisons, along with annual overviews to summarize findings across 
each calendar year. 
METHODOLOGY 
We obtained from CMS NDC-level ASP data from the first through 
fourth quarters of 2007, which were used to establish Part B drug 
reimbursement amounts for the third quarter of 2007 through the 
second quarter of 2008, respectively.  In addition, we obtained the files 
that CMS used to crosswalk NDCs to their corresponding HCPCS codes.  
We also obtained AMP data from CMS for the first through fourth 
quarters of 2007.15 
Comparing Volume-Weighted ASPs to Volume-Weighted AMPs for 2007 
Using the Revised ASP Payment Methodology 
As mentioned previously, Medicare does not base reimbursement for 
covered drugs on NDCs; instead, it uses HCPCS codes.  Therefore, CMS 
 
14 OEI-03-07-00140, July 2007. 
15 ASP data from the first through fourth quarters of 2007 were current as of June 2007, 
September 2007, December 2007, and March 2008, respectively.  AMP data from the first 
through fourth quarters of 2007 were current as of May 2007, September 2007, November 
2007, and February 2008, respectively.  
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I N T R O D U C T I O N  
uses ASP information submitted by manufacturers for each NDC to 
calculate a volume-weighted ASP for each covered HCPCS code.   
Because pricing data in the fourth quarter of 2007 were                             
volume-weighted differently than in the other three quarters of 2007, 
results of OIGs separate pricing comparisons from each of the four 
quarters could not be readily combined and summarized for this 2007 
calendar year overview.  To address this issue, and to establish a more 
useful and consistent benchmark for comparisons of ASPs and AMPs 
over time, OIG opted to conduct its yearend overview using only the 
revised payment methodology.16  To that end, it was necessary to 
recalculate volume-weighted ASPs and AMPs for the first through third 
quarters of 2007 using the revised payment methodology.  Therefore, 
the results presented in this 2007 overview may differ from the results 
presented in each of the separate quarterly reports previously published 
by OIG. 
Appendix C provides a more detailed description of the methods we used 
to calculate volume-weighted ASPs and AMPs. 
For each quarter of 2007, we compared the volume-weighted ASPs and 
AMPs calculated under the revised payment methodology and identified 
HCPCS codes with ASPs that exceeded the AMPs by at least 5 percent.   
For those HCPCS codes that met or exceeded the 5-percent threshold, 
we conducted a review of the associated NDCs to verify the accuracy of 
the billing unit information for the quarter(s) in which the threshold 
was met.  If HCPCS codes had potentially inaccurate billing units, we 
did not include them in our findings. 
To identify codes with ASPs that exceeded AMPs by at least 5 percent in 
one or more quarters of 2007, we then merged the results of the pricing 
comparisons from all four quarters.   
Analysis of Average Manufacturer Price Data That Were Missing or 
Unavailable in 2007 
We examined the number of NDCs for which manufacturers submitted 
ASP data but not AMP data, both in each quarter and across all four 
 
16Although this report applies the revised methodology to all four quarters of 2007, CMS 
was not required by law to calculate reimbursement using the revised method until the 
second quarter of 2008.  Because second-quarter 2008 reimbursement amounts were 
calculated using ASP data from the fourth quarter of 2007, CMS was only required to apply 
the new methodology to ASP data beginning with the fourth quarter of 2007.   
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II NN TT RR OO DD UU CC TT II OO NN   
quarters of 2007.  We also identified the number of drug codes that were 
removed from OIGs pricing comparisons because AMP data were either 
missing or unavailable.  For the purposes of this study, an AMP was 
considered missing if the manufacturer had a Medicaid rebate 
agreement in 2007 but did not submit a price for one or more quarters.  
An AMP was considered unavailable for an NDC if the manufacturer 
did not participate in the Medicaid drug rebate program and was 
therefore not required to submit AMP data to CMS. 
To determine whether a manufacturer participated in the Medicaid 
drug rebate program in 2007, we consulted the list of participating drug 
companies posted on CMSs Web site.   
Limitations 
We did not verify the accuracy of manufacturer-reported ASP and AMP 
data, nor did we verify the underlying methodology used by 
manufacturers to calculate ASPs and AMPs. 
Manufacturers are required to submit their quarterly ASP and AMP 
data to CMS 30 days after the close of the quarter.  Our analyses were 
performed on ASP and AMP data compiled by CMS soon after that 
deadline.  We did not determine whether manufacturers provided any 
revised and/or missing data to CMS at a later date. 
Furthermore, the definition of AMP changed in January 2007, such that 
AMPs must now be determined without regard to customary prompt 
pay discounts.17  Because manufacturers are still required to include 
customary prompt pay discounts in their ASP calculations, the dynamic 
between ASPs and AMPs may be different in this report as compared to 
that in OIG reports using prices submitted prior to 2007.   
Standards   
This inspection was conducted in accordance with the Quality 
Standards for Inspections issued by the Presidents Council on 
Integrity and Efficiency and the Executive Council on Integrity and 
Efficiency. 
 
17 Section 1927(k)(1) of the Act (as amended by section 6001(c)(1) of the DRA) and Medicaid 
Drug Rebate Program Bulletin for Participating Drug Manufacturers, Release No. 76, 
December 15, 2006. 
  OEI-03-08-00450  COMPARISON OF ASPS AND AMPS: AN OVERVIEW OF 2007  8   
 
   
 F I N D I N G S  
If the revised payment methodology had been      In April 2008, CMS began 
volume-weighting ASP data 
in effect throughout 2007, 71 drug codes     
using a revised methodology 
would have met the 5-percent threshold     
mandated by section 112(a) of the 
in at least one quarter 
Extension Act.18  If this revised 
payment methodology had been used to volume-weight pricing data 
from the first through fourth quarters of 2007, ASPs for 71 HCPCS 
codes would have exceeded the AMPs by at least 5 percent in at least 
one quarter. 
Appendix D presents a list of the 71 HCPCS codes, along with the 
quarter(s) in which each would have met the 5-percent threshold under 
the revised payment methodology. 
One-fourth of these drug codes (18 of 71) would have met the 5-percent 
threshold during multiple quarters of 2007 
If the revised payment methodology had been in effect for all of 2007, 
ASPs for three HCPCS codes (J1364, J2690, and Q0169) would have 
exceeded the AMPs by at least 5 percent in every quarter.  An 
additional three HCPCS codes would have met the 5-percent threshold 
in three of the four quarters.  For another 12 HCPCS codes, ASPs would 
have exceeded AMPs by at least 5 percent in two quarters.  
 
In comparing ASPs to AMPs, 
Additional codes may have met the     
OIG typically examines only 
5-percent threshold in 2007; however, missing or 
those HCPCS codes with 
unavailable AMPs prevented OIG from performing 
AMP data for every NDC 
pricing comparisons on these codes 
that was used to establish 
the Medicare reimbursement 
amount.  Therefore, missing or unavailable AMP data can significantly 
reduce the number of drug codes that are evaluated pursuant to 
sections 1847A(d)(2)(B) and 1847A(d)(3) of the Act.  For the purposes of 
this study, an AMP was considered missing if the manufacturer had a 
Medicaid rebate agreement in 2007 but did not submit a price for one or 
more quarters.  An AMP was considered unavailable for an NDC if the 
 
18 There is a two-quarter lag between the sales period for which ASPs are reported and the 
effective date of reimbursement amounts based on those ASPs.  Therefore, the 
methodological changes that went into effect in April 2008 were applied by CMS to ASP 
data from two quarters prior (i.e., the fourth quarter of 2007). 
  OEI-03-08-00450  COMPARISON OF ASPS AND AMPS: AN OVERVIEW OF 2007  9   
 
   
FFF III NNN DDD III NNN GGG SSS    
manufacturer did not participate in the Medicaid drug rebate program 
and was therefore not required to submit AMP data to CMS. 
Almost half of NDCs without AMP data belonged to manufacturers with 
Medicaid drug rebate agreements   
A total of 1,185 NDCs had no AMP data during one or more quarters of 
2007.  Manufacturers for almost half of these NDCs (529 of 1,185) 
participated in the Medicaid drug rebate program in 2007 and were 
therefore generally required to submit AMP data.19  For 14 percent of 
these NDCs (74 of 529), manufacturers did not submit AMP data for 
any quarter of 2007.  The majority (52 percent) of the 529 NDCs with 
missing AMP data belonged to two manufacturers.  
Manufacturers for the remaining 656 of 1,185 NDCs did not participate in 
the Medicaid drug rebate program in 2007 and therefore were not required 
to submit AMP data during that time.   
As a result of NDCs without AMP data, the number of pricing comparisons 
performed in 2007 was reduced by at least 25 percent 
In 2007, the number of NDCs with ASPs but no AMPs fluctuated from 
quarter to quarter, with the second and fourth quarters having more 
NDCs without AMPs.  In the first and third quarters of 2007, about    
one-fourth of HCPCS codes were excluded from OIGs pricing 
comparisons because AMP data were missing or unavailable for one or 
more of the associated NDCs.20  In the second and fourth quarters of 
2007, over 40 percent of HCPCS codes were excluded from OIGs pricing 
comparisons because AMP data were missing or unavailable.  Table 1 
on the next page lists the number of NDCs without AMP data in each 
quarter, as well as the number and percentage of HCPCS codes that 
were excluded from our analysis as a result of NDCs without AMPs. 
 
19 Although manufacturers with rebate agreements are generally required to submit AMP 
data, there may be valid reasons as to why AMP data were not provided for a specific NDC 
in a given quarter.  For example, a manufacturer may not necessarily be required to submit 
an AMP if the drug product has been terminated and there was no Medicaid drug 
utilization during the quarter.  
20 Relative to the total number of HCPCS codes in each quarter with Medicare 
reimbursement amounts based on the ASP payment methodology.  
  OEI-03-08-00450  COMPARISON OF ASPS AND AMPS: AN OVERVIEW OF 2007  10   
 
   
F I N D I N G S  
Table 1.  Impact of NDCs Without AMP Data on Quarterly Comparisons of ASPs to AMPs  
 
Percentage of 
  Number of NDCs With  Number of HCPCS Codes 
HCPCS Codes Excluded 
  ASP Data but    Excluded Because of  
Because of 
Quarter in 2007  No AMP Data  NDCs Without AMP Data 
NDCs Without AMP Data 
First Quarter  653  141  27% 
Missing  102 
  
Unavailable  551 
Second Quarter  880  211  41% 
Missing  355 
  
Unavailable  525 
Third Quarter   603  138   26% 
Missing  100 
  
Unavailable  503 
Fourth Quarter  1051  237  45% 
Missing  487 
  
Unavailable  564 
Source:  OIG analysis of ASP and AMP data from the first through fourth quarters of 2007. 
 
As a result of NDCs without AMP data, no pricing comparisons were 
performed on over 100 drug codes in 2007 
Because of NDCs without AMP data, a total of 268 different HCPCS 
codes were excluded from OIGs pricing comparisons during one or more 
quarters of 2007.  For 106 of these codes, we were unable to perform any 
pricing comparisons for the entire year because AMPs were missing or 
unavailable for one or more of the associated NDCs.    
 
  OEI-03-08-00450  COMPARISON OF ASPS AND AMPS: AN OVERVIEW OF 2007  11   
 
   
 R E C O M M E N D A T I O N S  
This is OIGs eighth report comparing ASPs to AMPs since the ASP 
reimbursement methodology for Part B prescription drugs took effect in 
January 2005.  Section 1847A(d)(3)(C) of the Act directs the Secretary to 
lower reimbursement amounts for drugs with ASPs that exceed AMPs 
by at least 5 percent.  Although CMS has acknowledged the Secretarys 
authority to adjust Part B reimbursement amounts based on the 
findings of OIGs pricing comparisons, the agency has yet to make any 
changes as a result of these studies.  In addition, CMS has not specified 
the process by which it will make reimbursement adjustments for drugs 
that meet the 5-percent threshold. 
This current study, which summarizes data across all four quarters of 
2007, identifies 71 drug codes that would have been eligible for price 
adjustment if CMSs revised ASP payment methodology had been in 
effect throughout 2007.  One-fourth of the 71 drug codes would have met 
the 5-percent threshold during multiple quarters of 2007.  
Additional codes may have been eligible for price adjustments based on 
data from 2007; however, missing and unavailable AMPs prevented 
OIG from performing pricing comparisons on at least 25 percent of codes 
in each quarter.  Manufacturers for almost half of the NDCs without 
AMPs participated in the Medicaid drug rebate program in 2007 and 
were therefore generally expected to submit AMP data.   
Consistent with statutory requirements, we recommend that CMS:  
Develop a Process To Adjust Payment Amounts Based on the Results of 
OIGs Pricing Comparisons   
CMS could specify the circumstances under which it will make 
adjustments, the time period(s) to which the adjustments would apply, 
and the length of time the adjustments will remain in effect. 
Subsequently Lower Medicare Reimbursement Amounts for Drugs With 
ASPs That Meet the 5-Percent Threshold Specified in Section 1847A(d)(3) of 
the Act 
CMS may want to focus specifically on those drugs that, according to 
OIGs yearend review, would have met the 5-percent threshold in 
multiple quarters.   
  OEI-03-08-00450  COMPARISON OF ASPS AND AMPS: AN OVERVIEW OF 2007  12   
 
   
R E C O M M E N D A T I O N S  
Continue To Explore and Undertake a Range of Efforts To Ensure That Drug 
Manufacturers Are Submitting the Required AMP Data in a Timely Manner, 
Including Collaborating With OIG About Administrative Remedies for 
Noncompliance                                                                                                                         
CMS should continue to evaluate and pursue appropriate actions against 
those manufacturers that fail to submit required data.  This may include 
termination actions and referrals to OIG for the pursuit of civil monetary 
penalty actions.  In doing so, CMS could focus on those manufacturers 
with either a relatively large percentage of missing AMP data or 
manufacturers that consistently fail to submit AMP data by the statutory 
deadline. 
AGENCY COMMENTS AND OFFICE OF INSPECTOR GENERAL 
RESPONSE 
CMS concurred with our recommendation to develop a process for 
adjusting payment amounts based on the results of OIGs pricing 
comparisons.  However, CMS did not specifically concur with our 
recommendation to lower Medicare reimbursement for drugs that meet 
the 5-percent threshold specified in section 1847A(d)(3) of the Act.  
Rather, CMS emphasized both the complexity of substituting payment 
amounts and the importance of proceeding cautiously as it seeks to 
understand the appropriate threshold percentage for pricing 
substitutions.  CMS expressed a desire to better understand differences 
between ASPs and AMPs, as well as to engage stakeholders 
(particularly drug manufacturers affected by potential price 
substitutions) and provide adequate notice when developing its pricing 
substitution policies.  In response to our final recommendation, CMS 
stated that it will continue its efforts to ensure that manufacturers are 
submitting required AMP data in a timely manner and that it supports 
adequate enforcement action against those that fail to comply with 
reporting requirements.   
OIG acknowledges that CMS must make complex decisions regarding 
price substitutions for eligible drugs, including the circumstances under 
which substitutions will be made, the effective date of such 
substitutions, and the time period for which the substitutions will 
remain in effect.  However, consistent with statutory requirements, we 
continue to recommend that Medicare reimbursement amounts for 
eligible codes be lowered pursuant to section 1847A(d)(3) of the Act, 
particularly for codes that meet the threshold percentage in multiple 
quarters.  OIG will continue to assist CMS, both in developing a timely 
  OEI-03-08-00450  COMPARISON OF ASPS AND AMPS: AN OVERVIEW OF 2007  13   
 
   
R E C O M M E N D A T I O N S  
and effective price substitution policy and in taking appropriate action 
against manufacturers that fail to comply with AMP-reporting 
requirements.      
For the full text of CMSs comments, see Appendix E. 
 
 
  OEI-03-08-00450  COMPARISON OF ASPS AND AMPS: AN OVERVIEW OF 2007  14   
 
   
 AAA PPP PPP EEE NNN DDD III XXX     ~~~     AAA    
Equations Used by the Centers for Medicare & Medicaid Services To 
Calculate Volume-Weighted Average Sales Prices  
In the following equations, a billing unit is defined as the number of Healthcare 
Common Procedure Coding System (HCPCS) code units that are contained in a 
national drug code (NDC). 
 
 
1. The Revised Equation Used by the Centers for Medicare & Medicaid Services 
(CMS) To Calculate Volume-Weighted Average Sales Prices (ASP) Beginning 
April 1, 2008 
 
 
  Volume-Weighted ASP   Sum of  (ASP for NDC * Number of NDCs Sold) 
=  
for the Billing Unit of  
  Sum of   (Number of NDCs Sold * Billing Units in NDC) 
 HCPCS Code 
 
 
 
2. The Equation Used by CMS To Calculate Volume-Weighted ASPs Prior to 
April 1, 2008 
 
 
   ASP for NDC 
* Number of NDCs Sold 
  Volume-Weighted ASP   Sum of 
Billing Units in NDC 
  for the Billing Unit of  
=  
 HCPCS Code 
  Sum of Number of NDCs Sold  
 
 
 
  OEI-03-08-00450  COMPARISON OF ASPS AND AMPS: AN OVERVIEW OF 2007  15   
 
   
 A P P E N D I X   ~   B  
Previous Office of Inspector General Reports Comparing Average Sales 
Prices and Average Manufacturer Prices 
 
(cid:132)  Monitoring Medicare Part B Drug Prices:  A Comparison of Average 
Sales Prices to Average Manufacturer Prices (OEI-03-04-00430), 
April 2006. 
 
(cid:132)  Comparison of Fourth-Quarter 2005 Average Sales Prices to Average 
Manufacturer Prices:  Impact on Medicare Reimbursement for Second 
Quarter 2006 (OEI-03-06-00370), July 2006.  
 
(cid:132)  Comparison of Third-Quarter 2006 Average Sales Prices to Average 
Manufacturer Prices:  Impact on Medicare Reimbursement for First 
Quarter 2007 (OEI-03-07-00140), July 2007. 
 
(cid:132)  Comparison of First-Quarter 2007 Average Sales Prices to Average 
Manufacturer Prices:  Impact on Medicare Reimbursement for Third 
Quarter 2007 (OEI-03-07-00530), September 2007. 
 
(cid:132)  Comparison of Second-Quarter 2007 Average Sales Prices to Average 
Manufacturer Prices:  Impact on Medicare Reimbursement for Fourth 
Quarter 2007 (OEI-03-08-00010), December 2007. 
 
(cid:132)  Comparison of Third-Quarter 2007 Average Sales Prices to Average 
Manufacturer Prices:  Impact on Medicare Reimbursement for First 
Quarter 2008 (OEI-03-08-00130), May 2008. 
 
(cid:132)  Comparison of Fourth-Quarter 2007 Average Sales Prices to Average 
Manufacturer Prices:  Impact on Medicare Reimbursement for Second 
Quarter 2008 (OEI-03-08-00340), August 2008. 
 
 
  OEI-03-08-00450  COMPARISON OF ASPS AND AMPS: AN OVERVIEW OF 2007  16   
 
   
II NN TT RR OO DD UU CC TT II OO NN   
 A P P E N D I X   ~   C  
Detailed Methodology for Calculating Volume-Weighted Average Sales Prices 
and Average Manufacturer Prices for 2007  
Before computing quarterly volume-weighted average sales prices (ASP) 
and average manufacturer prices (AMP) for 2007, it was necessary to 
identify the national drug codes (NDC) that should be included in each 
quarters calculations and convert AMPs so that they would be 
comparable to ASPs.  
Analysis of 2007 ASPs 
When calculating volume-weighted ASPs under the revised ASP 
payment methodology, we included only those NDCs that the Centers 
for Medicare & Medicaid Services (CMS) deemed valid in each quarter 
of 2007.  We did not examine NDCs that CMS opted to exclude from its 
own calculation of volume-weighted ASPs each quarter, nor did we 
verify the accuracy of CMSs crosswalk files. 
Analysis of 2007 AMPs 
An AMP is reported for the lowest identifiable quantity of the drug 
contained in the NDC (e.g., 1 milligram, 1 milliliter, 1 tablet, 1 capsule).  
In contrast, an ASP is reported for the entire amount of the drug 
contained in the NDC (e.g., for 50 milliliters, for 100 tablets).  To ensure 
that AMPs would be comparable to ASPs, it was necessary to convert 
the AMPs for each NDC in each quarter so that they represented the 
total amount of the drug contained in that NDC.   
In making these conversions, we examined AMPs only for those              
NDCs that CMS used in its calculation of volume-weighted ASPs for a 
given quarter.  If AMP data were not available for one or more of these 
NDCs, we excluded the corresponding Healthcare Common Procedure 
Coding System (HCPCS) code from our analysis of that quarters data.  
For each quarter, we then multiplied the AMPs for the remaining NDCs 
by the total amount of the drug contained in each NDC, as identified by 
sources such as the CMS crosswalk file, manufacturer Web sites, the 
Red Book, and the Food and Drug Administrations NDC directory.  
We will refer to the resulting amounts as converted AMPs.  If we could 
not successfully identify the amount of the drug reflected by the ASP in 
a given quarter and therefore could not calculate a converted AMP, we 
excluded the corresponding HCPCS codes from our analysis of that 
quarter.   
  OEI-03-08-00450  COMPARISON OF ASPS AND AMPS: AN OVERVIEW OF 2007  17   
 
   
A P P E N D I X   ~   C  
Using the converted AMPs for the remaining NDCs, we then calculated 
the quarterly volume-weighted AMP for each of the codes, consistent 
with the revised methodology for calculating volume-weighted ASPs.     
  OEI-03-08-00450  COMPARISON OF ASPS AND AMPS: AN OVERVIEW OF 2007  18   
 
   
 AA PP PP EE NN DD II XX    ~~    DE   
A P P E N D I X   ~   D  
 
Seventy-one Healthcare Common Procedure Coding System Codes With 
Average Sales Prices That Exceeded Average Manufacturer Prices by at 
Least 5 Percent in 2007 Under the Revised Payment Methodology 
Quarter(s) in Which the Codes Met the 5-Percent Threshold  
HCPCS             First   Second   Third    Fourth  
Code  Quarter    Quarter  Quarter    Quarter   
J1364  X  X  X  X 
J2690  X  X  X  X 
Q0169  X  X  X  X 
J2800  X  X  X   
J7505  X  X  X   
J1120    X  X  X 
J1457  X  X      
J1756  X  X      
J1790  X  X      
J2321  X  X      
J2440  X  X      
J9065  X    X   
J9250  X    X   
J9260  X    X   
J0476    X  X   
J2370    X  X   
J3315  X       X 
J2760    X     X 
J0456  X        
J0770  X        
J0780  X        
J1940  X        
J2545  X        
J3230  X        
J3410  X        
J3475  X        
J7608  X        
J8530  X        
J8560  X        
J9060  X        
J9062  X        
J9360  X        
Q0171  X        
Q0172  X        
J0280    X      
J0637    X      
J2060    X      
  OEI-03-08-00450  COMPARISON OF ASPS AND AMPS: AN OVERVIEW OF 2007  19   
 
   
A P P E N D I X   ~   D  
Quarter(s) in Which the Codes Met the 5-Percent Threshold  
HCPCS             First   Second   Third    Fourth  
Code  Quarter    Quarter  Quarter    Quarter   
J3070    X      
J3465    X      
J9175    X      
J9340    X      
J0210      X   
J0636      X   
J0800      X   
J1240      X   
J1580      X   
J1800      X   
J1840      X   
J1850      X   
J2150      X   
J2430      X   
J2560      X   
J2675      X   
J2700      X   
J2730      X   
J3000      X   
J7500      X   
J7620      X   
J7631      X   
J7669      X   
J9050      X   
J9190      X   
J9208      X   
Q0175      X   
Q0176      X   
J0300         X 
J1270         X 
J1441         X 
J1626         X 
J2505         X 
Q0168         X 
Source:  Office of Inspector Generals analysis of ASP and AMP data from the first through fourth quarters of 
2007. 
  OEI-03-08-00450  COMPARISON OF ASPS AND AMPS: AN OVERVIEW OF 2007  20   
 
   
 A P P E N D I X   ~   E  
    Agency Comments 
  OEI-03-08-00450  COMPARISON OF ASPS AND AMPS: AN OVERVIEW OF 2007  21   
 
   
AA PP PP EE NN DD II XX    ~~    EE   
 
  OEI-03-08-00450  COMPARISON OF ASPS AND AMPS: AN OVERVIEW OF 2007  22   
 
   
AA PP PP EE NN DD II XX    ~~    EE   
 
  OEI-03-08-00450  COMPARISON OF ASPS AND AMPS: AN OVERVIEW OF 2007  23   
 
   
 A C K N O W L E D G M E N T S  
 
This report was prepared under the direction of Robert A. Vito, Regional 
Inspector General for Evaluation and Inspections in the Philadelphia 
regional office, and David E. Tawes, Director of the Medicare and 
Medicaid Prescription Drug Unit.   
Lauren McNulty served as the team leader for this study.  Central office 
staff who contributed to this report include Kevin Manley.  
 
  OEI-03-08-00450  COMPARISON OF ASPS AND AMPS: AN OVERVIEW OF 2007  24