Persius/hicric huggingface dataset:
August 12, 2022 
TO:  Chiquita Brooks-LaSure 
Administrator 
Centers for Medicare & Medicaid Services 
FROM:   Suzanne Murrin  ERIN BLISS Digitally signed by ERIN BLISS 
Date: 2022.08.11 16:46:47 
Deputy Inspector General  -04'00'
on behalf of Suzanne Murrin
   for Evaluation and Inspections 
SUBJECT:  Comparison of Average Sales Prices and Average Manufacturer Prices: Results 
for the First Quarter of 2022, OEI-03-22-00210 
This memorandum summarizes the results of the Office of Inspector Generals (OIGs) 
comparison of average sales prices (ASPs) and average manufacturer prices (AMPs) for the 
first quarter of 2022.  By law, OIG must notify the Secretary of Health and Human Services if 
the ASP for a particular drug exceeds the drugs AMP by 5 percent or more.  If that threshold is 
met, the Secretary may disregard the drugs ASP when setting the reimbursement amount and 
substitute the lesser of either the widely available market price or 103 percent of the AMP.  
In April 2013, the Centers for Medicare & Medicaid Services (CMS) began making price 
substitutions in accordance with the November 2012 final rule specifying the circumstances 
under which AMP-based price substitutions occur.  Pursuant to the rule, CMS substitutes 
103 percent of the AMP for the ASP-based reimbursement amount when OIG identifies a drug 
code that exceeds the 5-percent threshold for two consecutive quarters or three of the previous 
four quarters. CMS lowers reimbursement amounts only when ASP and AMP comparisons are 
based on the same set of drug products (i.e., based on complete AMP data).  To prevent CMS 
from inadvertently raising the Medicare reimbursement amount, a price substitution is not 
implemented if the substituted amount would exceed the ASP-based payment amount for the 
quarter in which the price substitution would take effect.  In addition, price substitutions are not 
implemented for drugs that the Food and Drug Administration (FDA) identifies as being in short 
supply. 
OIG found that in the first quarter of 2022, eight drug codes met CMSs price-substitution 
criteria by exceeding the 5-percent threshold for two consecutive quarters or three of the 
previous four quarters, on the basis of complete AMP data.  OIG found 10 additional drug codes 
that, on the basis of complete AMP data, exceeded the 5-percent threshold.  However, at the time 
of our analysis, FDA identified these drugs as being in short supply.  Another two drug codes  Page 2Chiquita Brooks-LaSure 
had ASPs that exceeded the AMPs by at least 5 percent in the first quarter of 2022, on the basis 
of complete AMP data, but these drug codes did not meet other CMS price-substitution criteria.    
 
We will provide you with the results of our pricing comparison for the first quarter of 2022, as 
well as the results for the three previous quarters.  This information will be transmitted via our 
secure file transfer system.
May 13, 2022 
TO:  Chiquita Brooks-LaSure 
Administrator 
Centers for Medicare & Medicaid Services 
ANN  Digitally signed by
FROM:  Suzanne Murrin 
ANN MAXWELL
Deputy Inspector General 
   for Evaluation and Inspections  MAXWELL  Date: 2022.05.12
16:45:08 -04'00' 
SUBJECT:  Comparison of Average Sales Prices and Average Manufacturer Prices: Results 
for the Fourth Quarter of 2021, OEI-03-22-00200 
This memorandum summarizes the results of the Office of Inspector Generals (OIGs) 
comparison of average sales prices (ASPs) and average manufacturer prices (AMPs) for the 
fourth quarter of 2021.  By law, OIG must notify the Secretary of Health and Human Services if 
the ASP for a particular drug exceeds the drugs AMP by 5 percent or more.  If that threshold is 
met, the Secretary may disregard the drugs ASP when setting the reimbursement amount and 
substitute the lesser of either the widely available market price or 103 percent of the AMP.  
In April 2013, the Centers for Medicare & Medicaid Services (CMS) began making price 
substitutions in accordance with the November 2012 final rule specifying the circumstances 
under which AMP-based price substitutions occur.  Pursuant to the rule, CMS substitutes 
103 percent of the AMP for the ASP-based reimbursement amount when OIG identifies a drug 
code that exceeds the 5-percent threshold for 2 consecutive quarters or 3 of the previous 
4 quarters.  CMS lowers reimbursement amounts only when ASP and AMP comparisons are 
based on the same set of drug products (i.e., based on complete AMP data).  To prevent CMS 
from inadvertently raising the Medicare reimbursement amount, a price substitution is not 
implemented if the substituted amount would exceed the ASP-based payment amount for the 
quarter in which the price substitution would take effect.  In addition, price substitutions are not 
implemented for drugs that the Food and Drug Administration (FDA) identifies as being in short 
supply. 
OIG found that in the fourth quarter of 2021, 8 drug codes met CMSs price-substitution criteria 
by exceeding the 5-percent threshold for 2 consecutive quarters or 3 of the previous 4 quarters, 
on the basis of complete AMP data. OIG found 8 additional drug codes that, on the basis of 
complete AMP data, exceeded the 5-percent threshold.  However, at the time of our analysis, 
FDA identified these drugs as being in short supply. Another 4 drug codes had ASPs that  Page 2Chiquita Brooks-LaSure 
exceeded the AMPs by at least 5 percent in the fourth quarter of 2021, on the basis of complete 
AMP data, but these drug codes did not meet other CMS price-substitution criteria.    
We will provide you with the results of our pricing comparison for the fourth quarter of 2021, as 
well as the results for the three previous quarters.  This information will be transmitted via our 
secure file transfer system.
November 10, 2021 
TO:   Chiquita Brooks-LaSure 
Administrator 
Centers for Medicare & Medicaid Services  
Digitally signed 
SUZANNE 
FROM:   Suzanne Murrin  by SUZANNE 
Deputy Inspector General  MURRIN 
MURRIN 
   for Evaluation and Inspections  Date: 2021.11.09 
15:01:55 -05'00' 
SUBJECT:  Comparison of Average Sales Prices and Average Manufacturer Prices: Results 
for the Second Quarter of 2021, OEI-03-22-00060 
This memorandum summarizes the results of the Office of Inspector Generals (OIGs) 
comparison of average sales prices (ASPs) and average manufacturer prices (AMPs) for the 
second quarter of 2021.  By law, OIG must notify the Secretary of Health and Human Services if 
the ASP for a particular drug exceeds the drugs AMP by 5 percent or more.  If that threshold is 
met, the Secretary may disregard the drugs ASP when setting the reimbursement amount and 
substitute the lesser of either the widely available market price or 103 percent of the AMP.   
In April 2013, the Centers for Medicare & Medicaid Services (CMS) began making price 
substitutions in accordance with the November 2012 final rule specifying the circumstances 
under which AMP-based price substitutions occur.  Pursuant to the rule, CMS substitutes 
103 percent of the AMP for the ASP-based reimbursement amount when OIG identifies a drug 
code that exceeds the 5-percent threshold for 2 consecutive quarters or 3 of the previous 4 
quarters.  CMS lowers reimbursement amounts only when ASP and AMP comparisons are based 
on the same set of drug products (i.e., based on complete AMP data).  To prevent CMS from 
inadvertently raising the Medicare reimbursement amount, a price substitution is not 
implemented if the substituted amount would exceed the ASP-based payment amount for the 
quarter in which the price substitution would take effect.  In addition, price substitutions are not 
implemented for drugs that the Food and Drug Administration (FDA) identifies as being in short 
supply.  
OIG found that in the second quarter of 2021, 7 drug codes met CMSs price-substitution criteria 
by exceeding the 5-percent threshold for 2 consecutive quarters or 3 of the previous 4 quarters, 
based on complete AMP data.  OIG found 6 additional drug codes that, based on complete AMP 
data, exceeded the 5-percent threshold.  However, at the time of our analysis, FDA identified 
these drug codes as being in short supply.  Another 4 drug codes had ASPs that exceeded the  Page 2Chiquita Brooks-LaSure 
AMPs by at least 5 percent in the second quarter of 2021, based on complete AMP data, but 
these drug codes did not meet other CMS price-substitution criteria.    
 
We will provide you with the results of our pricing comparison for the second quarter of 2021, as 
well as the results for the three previous quarters.  This information will be transmitted via our 
secure file transfer system.
August 13, 2021
TO:  Chiquita Brooks-LaSure 
Administrator 
Centers for Medicare & Medicaid Services 
FROM:  Suzanne Murrin  ANN  Digitally signed by ANN 
Deputy Inspector General  MAXWELL 
   for Evaluation and Inspections  MAXWELL Date: 2021.08.13 
09:53:34 -04'00'
SUBJECT:  Comparison of Average Sales Prices and Average Manufacturer Prices: Results 
for the First Quarter of 2021, OEI-03-21-00080 
This memorandum summarizes the results of the Office of Inspector Generals (OIGs) 
comparison of average sales prices (ASPs) and average manufacturer prices (AMPs) for the first 
quarter of 2021.  By law, OIG must notify the Secretary of Health and Human Services if the 
ASP for a particular drug exceeds the drugs AMP by 5 percent or more.  If that threshold is met, 
the Secretary may disregard the drugs ASP when setting the reimbursement amount and 
substitute the lesser of either the widely available market price or 103 percent of the AMP.   
In April 2013, the Centers for Medicare & Medicaid Services (CMS) began making price 
substitutions in accordance with the November 2012 final rule specifying the circumstances 
under which AMP-based price substitutions occur.  Pursuant to the rule, CMS substitutes 
103 percent of the AMP for the ASP-based reimbursement amount when OIG identifies a drug 
code that exceeds the 5-percent threshold for two consecutive quarters or three of the previous 
four quarters.  CMS lowers reimbursement amounts only when ASP and AMP comparisons are 
based on the same set of drug products (i.e., based on complete AMP data).  To prevent CMS 
from inadvertently raising the Medicare reimbursement amount, a price substitution is not 
implemented if the substituted amount would exceed the ASP-based payment amount for the 
quarter in which the price substitution would take effect.  In addition, price substitutions are not 
implemented for drugs that the Food and Drug Administration (FDA) identifies as being in short 
supply.  
OIG found that in the first quarter of 2021, six drug codes met CMSs price-substitution criteria 
by exceeding the 5-percent threshold for two consecutive quarters or three of the previous four 
quarters, based on complete AMP data.  OIG found six additional drug codes that, based on 
complete AMP data, exceeded the 5-percent threshold.  However, at the time of our analysis, 
FDA identified these drug codes as being in short supply.  Another five drug codes had ASPs  Page 2Chiquita Brooks-LaSure 
that exceeded the AMPs by at least 5 percent in the first quarter of 2021, based on complete 
AMP data, but these drug codes did not meet other CMS price-substitution criteria.    
 
We will provide you with the results of our pricing comparison for the first quarter of 2021, as 
well as the results for the three previous quarters.  This information will be transmitted via our 
secure file transfer system.
TO:   Elizabeth Richter  
  Acting Administrator  
  Centers for Medicare & Medicaid Services  
 
 
FROM:   Suzanne Murrin  
Deputy Inspector General 
   for  Evaluation and Inspections  
 
 
SUBJECT:   Comparison of Average  Sales Prices and Average Manufacturer Prices:  Results  
for the Fourth Quarter of 2020, OEI-03-21-00070  
 
 
This memorandum summarizes the results of the Office of  Inspector Generals (OIGs) 
comparison of average sales prices (ASPs) and  average manufacturer prices  (AMPs) for the 
fourth quarter of 2020.  By law, OIG must notify the Secretary of Health and Human Services if  
the ASP for a particular  drug exceeds the drugs  AMP by 5 percent or more.  If that threshold is  
met, the Secretary may disregard the drugs ASP when setting the reimbursement amount and 
shall substitute the payment amount with the lesser of either the  widely available market price or  
103 percent of the AMP.    
 
In April 2013, the Centers for Medicare & Medicaid Services (CMS) began making price  
substitutions in accordance with the November 2012 final rule specifying the circumstances  
under which AMP-based price substitutions shall  occur.  Pursuant to the rule, CMS substitutes  
103 percent of the AMP  for the ASP-based reimbursement amount when OIG identifies a drug 
code that exceeds the 5-percent threshold for  two  consecutive quarters or  three of the previous  
four quarters.  CMS lowers reimbursement amounts only when ASP and AMP comparisons are  
based on the same set of  drug products (i.e., based on complete AMP data).  To prevent CMS  
from inadvertently raising the Medicare reimbursement amount, a price substitution shall not be  
implemented if the substituted amount would exceed the ASP-based payment amount for the  
quarter in which the price substitution would take effect.  Nor shall price substitutions be  
implemented for drugs that the Food and Drug Administration (FDA) identifies as being in short  
supply.  
 
In the  fourth  quarter of 2020, OIG found that  five  drug codes met CMSs price substitution 
criteria by  exceeding  the 5-percent threshold for  two  consecutive quarters  or three of the 
previous four  quarters, based on complete AMP data.   OIG found three additional drug codes  
that, based on complete  AMP data, exceeded the  5-percent threshold.  However, at the time of   Page 2Elizabeth  Richter  
our analysis, FDA  identified these  drug codes  as being in short supply.   Another  eight  drug codes  
had ASPs that exceeded the AMPs by at least 5 percent in the fourth  quarter of 2020, based on 
complete AMP data, but  these drug codes did not meet other CMS price-substitution criteria.     
 
We will provide you with the results of our pricing comparison for the  fourth  quarter of 2020, as  
well as the results for the  three previous quarters.  This information will be transmitted via our  
secure file transfer system.
February 12, 2021 
TO:   Elizabeth Richter 
Acting Administrator 
Centers for Medicare & Medicaid Services  
FROM:   Suzanne Murrin  for Suzanne Murrin 2/11/21 
Deputy Inspector General 
   for Evaluation and Inspections 
SUBJECT:  Comparison of Average Sales Prices and Average Manufacturer Prices: Results 
for the Third Quarter of 2020, OEI-03-21-00060 
This memorandum summarizes the results of the Office of Inspector Generals (OIGs) 
comparison of average sales prices (ASPs) and average manufacturer prices (AMPs) for the third 
quarter of 2020.  By law, OIG must notify the Secretary of Health and Human Services if the 
ASP for a particular drug exceeds the drugs AMP by 5 percent or more.  If that threshold is met, 
the Secretary may disregard the drugs ASP when setting the reimbursement amount and shall 
substitute the payment amount with the lesser of either the widely available market price or 
103 percent of the AMP. 
In April 2013, the Centers for Medicare & Medicaid Services (CMS) began making price 
substitutions in accordance with the November 2012 final rule specifying the circumstances 
under which AMP-based price substitutions shall occur.  Pursuant to the rule, CMS substitutes 
103 percent of the AMP for the ASP-based reimbursement amount when OIG identifies a drug 
code that exceeds the 5-percent threshold for two consecutive quarters or three of the previous 
four quarters.  CMS lowers reimbursement amounts only when ASP and AMP comparisons are 
based on the same set of drug products (i.e., based on complete AMP data).  To prevent CMS 
from inadvertently raising the Medicare reimbursement amount, a price substitution shall not be 
implemented if the substituted amount would exceed the ASP-based payment amount for the 
quarter in which the price substitution would take effect.  Nor shall price substitutions be 
implemented for drugs that the Food and Drug Administration (FDA) identifies as being in short 
supply. 
In the third quarter of 2020, OIG found that seven drug codes met CMSs price substitution 
criteria by exceeding the 5-percent threshold for two consecutive quarters or three of the 
previous four quarters, based on complete AMP data.  OIG found one additional drug code that,  Page 2Elizabeth Richter 
based on complete AMP data, exceeded the 5-percent threshold.  However, at the time of our 
analysis, FDA identified this drug code as being in short supply.  Another two drug codes had 
ASPs that exceeded the AMPs by at least 5 percent in the third quarter of 2020, based on 
complete AMP data, but these drug codes did not meet other CMS price-substitution criteria.    
We will provide you with the results of our pricing comparison for the third quarter of 2020, as 
well as the results for the three previous quarters.  This information will be transmitted via our 
secure file transfer system.
November 13, 2020 
TO:  Seema Verma, M.P.H. 
Administrator 
Centers for Medicare & Medicaid Services 
SUZANNE Digitally signed by 
SUZANNE MURRIN 
FROM:  Suzanne Murrin 
MURRIN  Date: 2020.11.12 
Deputy Inspector General 
15:42:21 -05'00' 
for Evaluation and Inspections 
SUBJECT:  Comparison of Average Sales Prices and Average Manufacturer Prices: Results 
for the Second Quarter of 2020, OEI-03-21-00050 
This memorandum summarizes the results of the Office of Inspector Generals (OIGs) 
comparison of average sales prices (ASPs) and average manufacturer prices (AMPs) for the 
second quarter of 2020.  By law, OIG must notify the Secretary of Health and Human Services if 
the ASP for a particular drug exceeds the drugs AMP by 5 percent or more.  If that threshold is 
met, the Secretary may disregard the drugs ASP when setting the reimbursement amount and 
shall substitute the payment amount with the lesser of either the widely available market price or  
103 percent of the AMP.  
In April 2013, the Centers for Medicare & Medicaid Services (CMS) began making price 
substitutions in accordance with the November 2012 final rule specifying the circumstances 
under which AMP-based price substitutions shall occur.  Pursuant to the rule, CMS substitutes 
103 percent of the AMP for the ASP-based reimbursement amount when OIG identifies a drug 
code that exceeds the 5-percent threshold for two consecutive quarters or three of the previous 
four quarters.  CMS lowers reimbursement amounts only when ASP and AMP comparisons are 
based on the same set of drug products (i.e., based on complete AMP data).  To prevent CMS 
from inadvertently raising the Medicare reimbursement amount, a price substitution shall not be 
implemented if the substituted amount would exceed the ASP-based payment amount for the 
quarter in which the price substitution would take effect.  Nor shall price substitutions be 
implemented for drugs that the Food and Drug Administration (FDA) identifies as being in short 
supply. 
In the second quarter of 2020, OIG found that seven drug codes met CMSs price substitution 
criteria by exceeding the 5-percent threshold for two consecutive quarters or three of the 
previous four quarters, based on complete AMP data. OIG found one additional drug code that, 
based on complete AMP data, exceeded the 5-percent threshold.  However, at the time of our  Page 2Seema Verma, M.P.H. 
analysis, FDA identified this drug code as being in short supply. Another seven drug codes had 
ASPs that exceeded the AMPs by at least 5 percent in the second quarter of 2020, based on 
complete AMP data, but these drug codes did not meet other CMS price-substitution criteria. 
We will provide you with the results of our pricing comparison for the second quarter of 2020, as 
well as the results for the three previous quarters.  This information will be transmitted via our 
secure file transfer system.
August 13, 2020 
TO:  Seema Verma, M.P.H. 
Administrator 
Centers for Medicare & Medicaid Services 
SUZANNE Digitally signed by 
FROM:  Suzanne Murrin  SUZANNE MURRIN 
Deputy Inspector GeneMralU  RRIN  Date: 2020.08.12 
for Evaluation and Inspections  18:19:52 -04'00' 
SUBJECT:  Comparison of Average Sales Prices and Average Manufacturer Prices: Results 
for the First Quarter of 2020, OEI-03-20-00060 
This memorandum summarizes the results of the Office of  Inspector Generals (OIGs) 
comparison of average sales prices (ASPs) and average manufacturer prices (AMPs) for the first 
quarter of 2020.  By law, OIG must notify the Secretary of Health and Human Services if the  
ASP for a particular drug exceeds the drugs AMP by 5 percent or more.  If that threshold is met, 
the Secretary may disregard the drugs ASP when setting the reimbursement amount and shall 
substitute the payment amount with the lesser of either the widely available market price or 
103 percent of the AMP.  
In  April 2013, the Centers for Medicare & Medicaid Services (CMS) began making price 
substitutions in accordance with the November 2012 final rule specifying the circumstances 
under which AMP-based price substitutions shall occur.  Pursuant to the rule, CMS substitutes 
103 percent of the AMP for the ASP-based reimbursement amount when OIG identifies a drug 
code that exceeds the 5-percent threshold for two consecutive quarters or three of the previous 
four quarters.  CMS lowers reimbursement amounts only when ASP and AMP comparisons are 
based on the same set of drug products (i.e., based on complete AMP data).  To prevent CMS 
from inadvertently raising the Medicare reimbursement amount, a price substitution shall not be 
implemented if the substituted amount would exceed the ASP-based payment amount for the 
quarter in which the price substitution would take effect.  Nor shall price substitutions be  
implemented for drugs that the Food and Drug Administration (FDA) identifies as being in short 
supply. 
OIG found that in the first quarter of 2020, eight drug codes met CMSs price substitution 
criteria by exceeding the 5-percent threshold for two consecutive quarters or three of the 
previous four quarters, based on complete AMP data.  OIG  found one additional drug code that, 
based on complete AMP data, exceeded the 5-percent threshold.  However,  at the time of our   Page 2Seema Verma, M.P.H. 
analysis, FDA identified this drug code as being in short supply.  Another two drug codes had 
ASPs that exceeded the AMPs by at least 5 percent in the first quarter of 2020, based on 
complete AMP data, but these drug codes did not meet other CMS price-substitution criteria. 
We will provide you with the results of our pricing comparison for the first quarter of 2020, as 
well as the results for the three previous quarters.  This information will be transmitted via our  
secure file transfer system.