Department of Health and Human Services

OFFICE OF 

INSPECTOR GENERAL 

C V -

ALCULATION OF  OLUME
W A S
EIGHTED  VERAGE  ALES 

P M P B 

RICE FOR  EDICARE  ART 
P D
RESCRIPTION  RUGS

Daniel R. Levinson

Inspector General 

February 2006

OEI-03-05-00310
 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 all 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 in order to reduce waste, abuse, and mismanagement and to promote economy 
and efficiency throughout HHS. 
Office of Evaluation and Inspections 
The Office of Evaluation and Inspections (OEI) conducts management and program evaluations 
(called inspections) that focus on issues of concern to HHS, Congress, and the public.  The 
findings and recommendations contained in the inspections generate rapid, accurate, and up-to-
date information on the efficiency, vulnerability, and effectiveness of departmental programs.  
OEI also oversees State Medicaid Fraud Control Units which investigate and prosecute fraud and 
patient abuse in the Medicaid program. 
Office of Investigations 
The Office of Investigations (OI) conducts criminal, civil, and administrative investigations of 
allegations of wrongdoing in HHS programs or to HHS beneficiaries and of unjust enrichment 
by providers.  The investigative efforts of OI lead to criminal convictions, administrative 
sanctions, 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 
in OIGs internal operations.  OCIG imposes program exclusions and civil monetary penalties on 
health care providers and litigates those actions within HHS.  OCIG also represents OIG in the 
global settlement of cases arising under the Civil False Claims Act, develops and monitors 
corporate integrity agreements, develops compliance program guidances, renders advisory 
opinions on OIG sanctions to the health care community, and issues fraud alerts and other 
industry guidance.  I N T R O D U C T I O N
  E X E C U T I V E   S U M M A R Y  

OBJECTIVE 
To review the Centers for Medicare & Medicaid Services (CMS) 
methodology for calculating volume-weighted average sales price (ASP) 
for Medicare Part B prescription drugs. 
BACKGROUND 
In January 2005, Medicare began paying for most Part B drugs using an 
entirely new pricing methodology based on ASPs.  Manufacturers report 
ASPs by national drug codes (NDC), which are 11-digit identifiers that 
indicate the manufacturer, the product dosage form, and the package 
size of a drug.  Manufacturers must provide CMS with the ASP and 
sales volume for each of their NDCs on a quarterly basis.   
Although manufacturers submit ASP data by NDCs, CMS does not 
reimburse Medicare providers for drugs using NDCs.  Instead, CMS 
uses 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.  Given that Medicare reimbursement for Part B 
drugs is based on HCPCS codes rather than NDCs, and that 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. The NDC-level information in this crosswalk can then be used to 
calculate an ASP for each covered HCPCS code. 
When CMS calculates payment amounts for HCPCS codes, it must 
weight ASPs at the NDC level by the amount of the drug sold during the 
quarter.  Pursuant to section 1847A(b)(1) of the Social Security Act (the 
Act), the Medicare allowance for most Part B drug codes is then equal to 
106 percent of the volume-weighted ASPs for those HCPCS codes. 
Section 1847A(b)(3) of the Act specifies the way to calculate a volume-
weighted ASP based on information reported by manufacturers, and 
this calculation assumes that the unit of ASP submission is the lowest 
identifiable quantity of the drug (e.g., 1 milliliter, 1 tablet).  However, 
the Act also granted the Secretary of the Department of Health and 
Human Services (Secretary) discretion to establish a different unit for 
reporting ASPs.1  Acting on behalf of the Secretary, CMS opted to 
exercise this discretion and changed the unit of ASP submission to the 
1Social Security Act   1847A(b)(2)(B). 
  OEI-03-05-00310  CALCULATION OF VOLUME-WEIGHTED AVERAGE SALES PRICE  i  E X E C U T I V E   S U M M A R Y  
amount of the drug represented by the NDC.2  The amount of the drug 
represented by one NDC may differ from the amount of the drug 
represented by another NDC.  It may also differ from the amount of the 
drug specified by the HCPCS code. Therefore, collecting ASPs and sales 
volume by NDC means that there is no longer a standard unit across 
NDCs to use in calculating a volume-weighted ASP for the HCPCS code. 
To standardize the amount of the drug contained in each of the NDCs 
associated with a given HCPCS code, CMS introduced billing units into 
the calculation of volume-weighted ASPs.  The number of billing units 
in an NDC describes the number of HCPCS code units in that NDC. 
For this study, we obtained volume-weighted ASPs for the first quarter 
of 2005, which CMS calculated based on data submitted by 
manufacturers for the third quarter of 2004.  We reviewed CMSs 
calculations of volume-weighted ASPs for 459 HCPCS codes. We also 
developed an alternate method for calculating volume-weighted ASP 
and used this alternate method to calculate volume-weighted ASPs and 
reimbursement amounts for each of the 459 HCPCS codes. We then 
compared reimbursement amounts calculated using the alternate 
method to those calculated by CMS and identified codes for which the 
reimbursements differed.  We also estimated the monetary impact of 
using the Office of Inspector General (OIG) reimbursement methodology 
rather than the CMS reimbursement methodology. 
FINDINGS 
The method CMS uses to calculate volume-weighted average 
sales price is incorrect.  We believe that the method CMS uses to 
calculate a volume-weighted ASP for a HCPCS code is mathematically 
incorrect because CMS does not use billing units consistently 
throughout its equation.  Although CMS uses billing units to 
standardize ASPs across NDCs for each HCPCS code, it does not 
similarly standardize sales volume across NDCs.  As a result, CMSs 
equation may not always yield a volume-weighted ASP that is 
consistent with the volume-weighted ASP derived from the calculation 
set forth in the law.  Recognizing this inconsistency, OIG developed an 
alternate method for calculating the volume-weighted ASP, which 
produces a volume-weighted ASP that is both mathematically correct 
and consistent with the results of the calculation set forth in the ASP 
legislation. To illustrate this point, we calculated the volume-weighted 
242 C.F.R.  414.802 (2004). 
  OEI-03-05-00310  CALCULATION OF VOLUME-WEIGHTED AVERAGE SALES PRICE  ii  EEE XXX EEE CCC UUU TTT III VVV EEE     SSS UUU MMM MMM AAA RRR YYY
ASP for a HCPCS code using the calculation derived from section 
1847A(b)(3) of the Act, CMSs calculation, and OIGs alternate 
calculation. The calculation derived from the statute and OIGs 
alternate calculation both yielded the same volume-weighted ASP for 
the HCPCS code, whereas CMSs calculation yielded a different volume-
weighted ASP. 
Because CMS calculates volume-weighted ASPs incorrectly, current 
and future reimbursement amounts may not be accurate. According 
to our analysis of prices published in the first quarter of 2005, 
46 percent of HCPCS codes had a reimbursement amount that was 
higher than it should have been, resulting in an estimated $115 million 
loss to Medicare in 2005. For 13 percent of HCPCS codes, CMSs 
reimbursement amount was lower than it should have been, 
representing an estimated $5 million loss to providers in 2005. For the 
remaining 41 percent of HCPCS codes, there was no difference between 
the reimbursement amount calculated by CMS and the reimbursement 
amount calculated by OIG. In addition, CMSs incorrect calculation 
affects adjustments to drug reimbursement amounts based on OIG 
pricing comparisons mandated by the Medicare Prescription Drug, 
Improvement, and Modernization Act of 2003 (MMA). 
RECOMMENDATION 
Volume-weighted ASPs form the basis on which providers are 
reimbursed for most Part B drugs. Therefore, any inaccuracies in these 
amounts have significant implications for the Medicare program, its 
health care providers, and its beneficiaries. We believe that CMSs 
method for calculating volume-weighted ASPs is incorrect, and that the 
incorrect calculation can produce improper reimbursement amounts. 
Although we identified many HCPCS codes for which reimbursement 
was too high in the first quarter of 2005, we also found a number of 
HCPCS codes for which reimbursement was too low. Moreover, the 
ratio between codes with reimbursements that are too high and those 
with reimbursements that are too low may periodically fluctuate given 
that ASP data change from quarter to quarter. 
Furthermore, CMSs incorrect calculation has implications for future 
adjustments to reimbursement amounts based on OIG pricing 
comparisons mandated by the MMA. It is therefore critical that the 
calculation of volume-weighted ASPs be performed correctly for all 
HCPCS codes. 
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CMS should change its method for calculating volume-weighted ASPs. 
We propose that CMS adopt an alternate equation, which uses billing 
units consistently and produces a volume-weighted ASP that is both 
mathematically correct and consistent with the results of the calculation 
set forth in section 1847A(b)(3) of the Act. 
AGENCY COMMENTS 
CMS indicated that it will consider the reports findings in its ongoing 
efforts to enhance implementation of the new ASP payment 
methodology. CMS also stated that it presented the current ASP 
calculation in proposed rule 70 Fed. Reg. 45764, 45844 (August 8, 2005) 
and received public comments on its approach. As CMS gains more 
experience with the ASP data, and as more information becomes 
available, CMS stated that it may consider altering the ASP 
methodology. 
OFFICE OF INSPECTOR GENERAL RESPONSE 
We continue to believe that CMS is calculating volume-weighted ASP 
incorrectly, and that this incorrect calculation results in reimbursement 
amounts that are inaccurate and inconsistent with the ASP payment 
methodology set forth in section 1847A(b)(3) of the Act. According to 
our analysis of prices from the first quarter of 2005, the net effect of 
inaccurate payments was a loss for the Medicare Trust Fund. 
OIGs concerns about the ASP calculation were echoed in the comments 
CMS received on proposed rule 70 Fed. Reg. 45764, 45844 (August 8, 
2005). In response to the proposed rule, several manufacturers or their 
representatives noted that products are available in different package 
sizes and that a billing code may encompass multiple NDCs; therefore, 
weighting the ASP payment amount by NDCs sold does not reflect the 
true weighted average price per billing unit. These commenters 
suggested that CMS revise its calculation so that the payment limit is 
based on the weighted ASP of the number of billing units sold rather 
than the number of NDCs sold. Commenters on the proposed rule 
recognized that such a change could result in an increase or decrease to 
the reimbursement amount, but recommended that the calculation be 
altered nonetheless. 
We look forward to receiving CMSs comments on this final report. 
OEI-03-05-00310  CALCULATION OF VOLUME-WEIGHTED AVERAGE SALES PRICE  iv    T A B L E   O F   C O N T E N T S  

EXECUTIVE SUMMARY  .......................................  i

INTRODUCTION ................................................ 1 

FINDINGS .......................................................  6 

CMSs calculation of volume-weighted ASPs is incorrect . . . . . . . .  6

Reimbursement amounts may not be accurate . . . . . . . . . . . . . . . .  8

RECOMMENDATION ........................................... 11 

Agency Comments. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  11

Office of Inspector General Response. . . . . . . . . . . . . . . . . . . . . . .  11

APPENDIXES .................................................. 13 

A:	  Equations Used to Calculate Volume-Weighted ASP  . . . . . . .  13

B: 	Codes for Which CMSs Reimbursement Amount Exceeded     

OIGs ReimbursementAmount  . . . . . . . . . . . . . . . . . . . . . . . .  14

C: 	Codes for Which CMSs Reimbursement Amount Was Less   

Than OIGsReimbursement Amount. . . . . . . . . . . . . . . . . . . .  19

D: 	Codes for Which CMSs Reimbursement Amount and OIGs 

Reimbursement Amount Were theSame. . . . . . . . . . . . . . . . .  21

E:  Centers forMedicare &Medicaid Services Comments. . . . . .  26

ACKNOWLEDGMENTS ......................................... 27
   I N T R O D U C T I O N  

OBJECTIVE 
To review the Centers for Medicare & Medicaid Services (CMS) 
methodology for calculating volume-weighted average sales price (ASP) 
for Medicare Part B prescription drugs. 
BACKGROUND 
Medicare Coverage of Prescription Drugs 
Medicare Part B currently covers a limited number of outpatient 
prescription drugs.  Those that are covered 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. With 
the advent of the Part D benefit in 2006, Medicare will offer 
beneficiaries additional insurance coverage for certain outpatient 
prescription drugs that are not covered under Part B.   
Use of Average Sales Price in the Medicare Program 
In January 2005, Medicare began paying for most Part B drugs using an 
entirely new pricing methodology based on ASPs.1 Section 1847A(c) of 
the Social Security Act (the Act), as added by the Medicare Prescription 
Drug, Improvement, and Modernization Act of 2003 (MMA), P.L. 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, and cash discounts; free goods 
contingent on purchase requirements; chargebacks; and rebates other 
than those obtained through the Medicaid drug rebate program. 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.2 
1Prior to 2005, the pricing methodology for most Part B drugs was based on the average 
wholesale price (AWP).  For 2004, the reimbursement amount for most covered drugs was 
based on 85 percent of the AWP 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 AWP. 
2Pursuant 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. 
  OEI-03-05-00310  CALCULATION OF VOLUME-WEIGHTED AVERAGE SALES PRICE  1  I N T R O D U C T I O N  
Manufacturers Reporting of Average Sales Price Data 
Pursuant to section 1927(b)(3)(A)(iii) of the Act, manufacturers report 
ASPs by national drug codes (NDC), which are 11-digit identifiers that 
indicate the manufacturer, the product dosage form, and the package 
size of a 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 the quarter. 
Section 1847A(b)(2)(B) of the Act defines the unit of ASP submission as 
the lowest identifiable quantity (such as a capsule or tablet, milligram 
of molecules, or grams) of the drug or biological. Accordingly, 
manufacturers would submit, with respect to each NDC, the ASP and 
volume of sales for the smallest amount of the drug contained in the 
NDCe.g., manufacturers would submit an ASP for 1 milliliter and the 
number of 1-milliliter units sold.  However, section 1847A(b)(2)(B) of the 
Act also grants the Secretary of the Department of Health and Human 
Services (Secretary) discretion to establish a different unit for reporting 
ASPs for years after 2004. Acting on behalf of the Secretary, CMS opted 
to exercise this discretion and changed the unit of ASP submission from 
the lowest identifiable quantity of the drug (e.g., 1 milliliter, 1 tablet) to 
the amount of the drug represented by the NDC (e.g., 50 milliliters, 
100 tablets).3  Therefore, manufacturers currently report an ASP for the 
amount of the drug in the NDC rather than for the smallest identifiable 
quantity of the drug. 
Use of Healthcare Common Procedure Coding System Codes 
Although manufacturers submit ASP data by NDCs, CMS does not 
reimburse Medicare providers for drugs using NDCs.  Instead, CMS 
uses 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.  Each HCPCS code for drugs defines the drug 
name and dosage size but does not specify manufacturer information or 
package size data.   
Given that Medicare reimbursement for Part B drugs is based on 
HCPCS codes rather than NDCs, and that 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.  The NDC-
level information in this crosswalk can then be used to calculate an ASP 
for each covered HCPCS code. Under the ASP pricing methodology, the 
342 C.F.R.  414.802 (2004). 
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Medicare allowance for most Part B drugs is equal to 106 percent of the 
ASP for the HCPCS code. Medicare beneficiaries are responsible for 
20 percent of this amount in the form of coinsurance. 
Calculation of Volume-Weighted ASP 
Calculation of a Volume-Weighted ASP Based on the Methodology Set Forth in 
the Law. As mentioned above, manufacturers submit ASPs by NDCs, 
and more than one NDC may meet the definition of a HCPCS code. 
These multiple NDCs are then used to calculate an ASP for the HCPCS 
code. However, each NDC does not contribute equally toward the 
payment amount for a HCPCS code. Consistent with section 
1847A(b)(3) of the Act, when payment amounts for HCPCS codes are 
calculated, ASPs at the NDC level must be weighted by the amount of 
the drug sold during the quarter. This means that the ASP for a drug 
with a high volume of sales will have greater influence on the 
reimbursement amount for a HCPCS code than an ASP for a drug with 
a low volume of sales. Section 1847A(b)(3) of the Act describes the 
following equation for calculating volume-weighted ASP: 
Volume-Weighted ASP  Sum of  (ASP for One Unit * Number of Units Sold ) 
for One Unit  = 
Sum of Number of Units Sold 
This equation assumes that the unit of ASP submission, as defined in 
section 1847A(b)(2)(B) of the Act, is the lowest identifiable amount of 
the drug. Therefore, the equation yields a volume-weighted ASP for the 
lowest identifiable amount of the druge.g., a volume-weighted ASP for 
1 milliliter or 1 tablet. This amount can then be multiplied by the 
amount of the drug specified by the HCPCS code, which results in the 
volume-weighted ASP for the HCPCS code.4 For example, if a HCPCS 
code represents 5 milliliters of a drug, and the volume-weighted ASP for 
1 milliliter of the drug as determined by the calculation in the law is $2, 
then the volume-weighted ASP for the HCPCS code would be 5 times 
$2, or $10. 
Calculation of a Volume-Weighted ASP According to CMS. The calculation 
specified in the statute uses the lowest identifiable amount of the drug 
as the standard unit of the drug across NDCs. However, because CMS 
exercised its discretion and changed the unit of ASP submission from 
4The statute does not specifically address converting the volume-weighted ASP for the 
lowest identifiable amount of the drug to a reimbursement amount for the HCPCS code. 
However, the conversion can be achieved by multiplying the volume-weighted ASP for one 
unit by the amount of the drug specified by the HCPCS code. 
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the lowest identifiable amount of the drug to the entire amount of the 
drug represented by the NDC, the calculation described in the law could 
not be applied exactly as written. 5  The entire amount of the drug 
contained in an NDC may differ from one NDC to the next. It may also 
differ from the amount of the drug specified by the HCPCS code. 
Therefore, collecting ASPs and sales volume by NDCs means that there 
is no longer a standard unit across NDCs to use in calculating a volume-
weighted ASP for the HCPCS code. It was therefore necessary for CMS 
to modify the method for calculating a volume-weighted ASP described 
in the law. 
To standardize the amount of the drug contained in each of the NDCs 
associated with a given HCPCS code, CMS introduced billing units into 
the calculation of a volume-weighted ASP. The number of billing units 
in an NDC, which CMS calculates as part of its crosswalk files, 
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. The equation 
that CMS uses to calculate a volume-weighted ASP is as follows: 
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 
METHODOLOGY 
We obtained CMSs volume-weighted ASPs for the first quarter of 2005, 
which were calculated based on NDC-level data submitted by 
manufacturers for the third quarter of 2004. In addition, we obtained 
the file that CMS used to crosswalk NDCs to their corresponding 
HCPCS codes. Both the volume-weighted ASPs and the crosswalk file 
were updated as of January 13, 2005. 
As of January 13, 2005, CMS had established prices for 459 HCPCS 
codes based on the ASP reimbursement methodology. This total 
excludes HCPCS code J3490, which is defined as unclassified drugs. 
Reimbursement amounts for the 459 HCPCS codes were based on ASP 
data for 2,399 NDCs. We reviewed the method CMS used to calculate a 
volume-weighted ASP for each of the 459 HCPCS codes, examining each 
5Discretion to change the unit of ASP submission is permitted by section 1847A(b)(2)(B) of 
the Act. 
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step to ensure that CMSs calculation was mathematically correct. 
However, we did not verify the accuracy of the billing unit information 
contained in CMSs crosswalk file. 
We concluded that CMSs calculation was problematic, and therefore 
developed an alternate method for calculating a volume-weighted ASP 
and used this method to calculate alternate volume-weighted ASPs for 
each of the 459 HCPCS codes. Under this method, billing units are used 
as the standard unit across all NDCs for a particular HCPCS code, just 
as they are in CMSs calculation. However, the Office of Inspector 
Generals (OIG) calculation uses billing units differently than CMSs 
calculation. OIGs alternate equation is as follows: 
Volume-Weighted ASP  Sum of  (ASP for NDC * Number of NDCs Sold ) 
for the Billing Unit of  = 
HCPCS Code  Sum of (Number of NDCs Sold * Billing Units in NDC) 
As mentioned earlier, the Medicare allowance for a HCPCS code is 
equal to 106 percent of the volume-weighted ASP. Therefore, to 
determine what the Medicare reimbursement amount would be 
according to the alternate calculation, we multiplied OIGs volume-
weighted ASPs for each of the 459 codes by 1.06. We then compared our 
reimbursement amounts to CMSs reimbursement amounts and 
identified codes for which the reimbursements differed. To estimate the 
monetary impact of using the OIG reimbursement rather than the CMS 
reimbursement, we first subtracted OIGs first quarter 2005 
reimbursement amount from CMSs first quarter 2005 reimbursement 
amount for each HCPCS code. We then multiplied the difference by the 
number of services that were allowed by Medicare for each HCPCS code 
in 2004, as reported in CMSs Part B Extract and Summary System 
(BESS).6 This estimate assumes that the volume-weighted ASP for 
each HCPCS code will remain consistent throughout 2005. However, 
the ASP amounts submitted by manufacturers may actually vary from 
quarter to quarter. 
Standards 
This study 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. 
6At the time of extraction, BESS data were 96 percent complete for HCPCS codes processed 
by local carriers and 91 percent complete for HCPCS codes processed by the durable 
medical equipment regional carriers. 
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The method CMS uses to calculate volume- The method CMS uses to 
weighted average sales price is incorrect  calculate a volume-weighted 
ASP for a HCPCS code is 
mathematically incorrect because CMS does not use billing units 
consistently throughout its equation.  Although CMS uses billing units 
to standardize ASPs across NDCs for each HCPCS code, it does not 
similarly standardize sales volume across NDCs.  As a result, CMSs 
equation may not always yield the same volume-weighted ASP as that 
derived from the equation set forth in section 1847A(b)(3) of the Act.7 
To address this inconsistency, OIG developed an alternate method for 
calculating a volume-weighted ASP.  The alternate calculation corrects 
the deficiencies in CMSs calculation by multiplying the number of 
NDCs sold by the number of billing units in the NDC in both the 
numerator and denominator of the equation.  As a result, OIGs 
alternate calculation produces a volume-weighted ASP that is both 
mathematically correct and consistent with the results of the ASP 
calculation set forth in the Act.  A more detailed explanation of OIGs 
equation is presented in Appendix A.   
To illustrate this point, we calculated volume-weighted ASP for HCPCS 
code X using the calculation derived from the statute, CMSs 
calculation, and OIGs alternate calculation.  In this example, there are 
four different NDCs that meet the description of HCPCS code X, which 
is defined as 5 milliliters of Drug A. The table on the next page provides 
ASP information for each of the four NDCs.  Columns C and D 
demonstrate the way that manufacturers would have submitted the 
ASP data if CMS had used the original unit of ASP submission (i.e., the 
lowest identifiable quantity of the drug).  Columns E and F illustrate 
the way that manufacturers would currently submit the ASP and sales 
volume for each of the NDCs (i.e., in terms of NDC units).  Column G 
shows the number of 5-milliliter units that are contained in each of the 
four NDCs associated with HCPCS code X. 
As shown on the next page, CMSs calculation yields a volume-weighted 
ASP for HCPCS code X that is $0.73 higher than the volume-weighted 
ASP derived from either the calculation specified in section 1847A(b)(3) 
of the Act or OIGs alternate calculation. 
7The calculation described in section 1847A(b)(3) of the Act does consistently use a 
standardized unit (i.e., the lowest identifiable quantity of the drug).  
  OEI-03-05-00310  CALCULATION OF VOLUME-WEIGHTED AVERAGE SALES PRICE  6  F I N D I N G S  
  Calculating A Volume-Weighted ASP for HCPCS Code X (5 mL of Drug A) 
ASP Information for Four NDCs Associated With HCPCS Code X 
A  B  C  D  E  F  G 
Total Amount  ASP  Number  ASP  Number 
Billing Units 
NDC  of Drug  for One Unit  of 1-mL Units  for  of 
in NDC 
in NDC  (1 mL)  Sold  Entire NDC  NDCs Sold 
1  2 mL  $4.35  57,600  $8.70  28,800  0.4 
2  2 mL  $4.25  84,660  $8.50  42,330  0.4 
3  3 mL  $3.98  116,640  $11.94  38,880  0.6 
4  4 mL  $3.14  210,760  $12.56  52,690  0.8 
1.  Volume-Weighted ASP for HCPCS Code X Based on the Calculation in the Law 
Sum of (ASP for One Unit * Number of Units Sold) 
Amount of Drug Specified  Volume-Weighted ASP
* = 
by HCPCS Code   for HCPCS Code 
Sum of Number of Units Sold 
($4.35 * 57,600) + ($4.25 * 84,660) + ($3.98 * 116,640) + ($3.14 * 210,760) 
*  5 mL  =  $18.49 
57,600 + 84,660 + 116,640  +  210,760 
2.  Volume-Weighted ASP for HCPCS Code X Based on CMSs Calculation 
ASP for NDC
Sum of  * Number of NDCs Sold 
Billing Units in NDC 
Volume-Weighted ASP 
= 
for HCPCS Code 
Sum of Number of NDCs Sold  
$8.70  $8.50  $11.94  $12.56 
* 28,800  +  * 42,330  +  * 38,880  +  * 52,690 
0.4  0.4  0.6  0.8 
=  $19.22 
28,800 + 42,330 + 38,880  + 52,690 
3.  Volume-Weighted ASP for HCPCS Code X Based on OIGs Calculation 
Sum of (ASP for NDC * Number of NDCs Sold ) 
Volume-Weighted ASP 
= 
for HCPCS Code 
Sum of (Number of NDCs Sold * Billing Units in NDC) 
($8.70 * 28,800) + ($8.50 * 42,330) + ($11.94 * 38,880) + ($12.56 * 52,690) 
=  $18.49 
(28,800* 0.4) +  (42,330 * 0.4) +  (38,880 * 0.6) +  (52,690 * 0.8) 
  OEI-03-05-00310  CALCULATION OF VOLUME -WEIGHTED AVERAGE SALES PRICE  7  F FI IN ND DI IN NG GS
 S  
We believe that the discrepancy between CMSs results and the results 
of the other two calculations stems from the fact that CMS uses billing 
units to standardize ASPs but not the number of NDCs sold. In the 
numerator of its equation, CMS standardizes ASPs across NDCs by 
calculating an ASP per billing unit for each NDC. 8  However, CMS does 
not convert the number of NDCs sold into the number of billing units 
sold in the numerator, nor does CMS convert NDCs sold into billing 
units sold in the denominator.  Instead, CMS continues to use the 
number of NDCs sold. CMS treats these sales figures as if they 
represent a standard amount of the drug when, in fact, the amount of 
the drug in each NDC may vary from one NDC to the next.  Summing 
the number of NDCs sold across NDCs is similar to concluding that   
5 nickels, 2 dimes, and 1 quarter equals 8 cents because 5+2+1=8. 
Volume-weighted ASPs form the 
Because CMS calculates volume-weighted 
basis for the reimbursement of most 
ASPs incorrectly, current and future 
Part B drugs.  Therefore, the 
reimbursement amounts may not be accurate 
incorrect calculation of volume-
weighted ASPs has a significant impact on the Medicare program, its 
health care providers, and its beneficiaries. 
The method CMS uses to calculate volume-weighted ASPs often results in 
reimbursement amounts that are either too high or too low 
According to our analysis of data from the first quarter of 2005, almost 
60 percent of published HCPCS codes had a reimbursement amount 
that was either too high or too low when compared to the results of 
OIGs alternate calculation.  Reimbursement amounts for the remaining 
HCPCS codes would have been the same regardless of whether CMSs 
or OIGs calculation was used. 
For 46 percent of HCPCS codes, CMSs reimbursement amount was too high. 
For 212 of the 459 HCPCS codes, the Medicare reimbursement amount as 
calculated by CMS was higher than the Medicare reimbursement amount 
as calculated by OIG. Of these HCPCS codes, 18 had a reimbursement 
amount that was at least twice as much as it would have been using OIGs 
method, and 3 had a reimbursement amount that was at least 5 times 
what it would have been using the OIG method. 
8The ASP per billing unit is the ASP for the entire NDC divided by the number of billing 
units in the NDC.  In terms of the table on page 7, this would be Column E divided by 
Column G. 
  OEI-03-05-00310  CALCULATION OF VOLUME-WEIGHTED AVERAGE SALES PRICE  8  F I N D I N G
 S  
Based on the number of services allowed in 2004, the Medicare program 
and its beneficiaries would pay an estimated $115 million less in 2005 if 
reimbursement amounts were calculated using OIGs method rather 
than CMSs method. Adjusting the calculation for just two codes, J9217 
and J2275, would result in an estimated savings of almost $50 million 
for the Medicare program in the year 2005. 9 A list of all 212 HCPCS 
codes is presented in Appendix B. 
For 13 percent of HCPCS codes, CMSs reimbursement amount was too low. For 
61 of the 459 HCPCS codes, the Medicare reimbursement amount as 
calculated by CMS was lower than the Medicare reimbursement amount 
as calculated by OIG. Of these HCPCS codes, seven had a reimbursement 
amount that was at least 10 percent lower than it would have been using 
OIGs calculation. 
We estimate that providers who bill Medicare for the 61 HCPCS codes 
would gain about $5 million in the year 2005 if OIGs method for 
calculating a volume-weighted ASP were used instead of CMSs method.  
In fact, providers who bill Medicare for one HCPCS code alone, J2430, 
would receive an estimated $1.6 million more in the year 2005. 10 A list 
of all 61 HCPCS codes is presented in Appendix C. 
For the remaining 41 percent of HCPCS codes, there was no difference between 
the reimbursement amount calculated by CMS and the reimbursement amount 
calculated by OIG. CMS and OIG calculations yielded the same result for 
the remaining 186 HCPCS codes.  In these cases, CMSs inconsistent use 
of billing units did not affect the results, usually because there was only 
one NDC used to price the HCPCS code and therefore no need to weight 
the data by volume.  A list of these 186 HCPCS codes is presented in 
Appendix D. 
CMSs incorrect calculation of volume-weighted ASPs affects statutory 
mandates to monitor and adjust drug reimbursement amounts 
To monitor new reimbursement amounts based on ASPs, section 
1847A(d)(2)(B) of the Act mandates that OIG perform comparisons 
between ASPs and both average manufacturer prices (AMP) and widely 
available market prices (WAMP).  If OIG determines that the ASP for a 
drug exceeds either the AMP or the WAMP by 5 percent, the Secretary 
9HCPCS code J9217 represents leuprolide acetate (for depot suspension), 7.5 mg; and 
HCPCS code J2275 represents an injection of morphine sulfate (preservative-free sterile 
solution), per 10 mg.   
10HCPCS code J2430 represents an injection of pamidronate disodium, per 30 mg. 
  OEI-03-05-00310  CALCULATION OF VOLUME-WEIGHTED AVERAGE SALES PRICE  9  FF II NN DD II NN GG SS  
may substitute the payment amount for that drug product with the lower 
of either the WAMP or 103 percent of the AMP. 
CMSs incorrect calculation affects the outcome of future pricing 
comparisons performed by OIG, which in turn affect whether 
reimbursement amounts are lowered. If volume-weighted ASPs and 
volume-weighted AMPs are not calculated correctly, reimbursement 
amounts for some HCPCS codes may be lowered to 103 percent of the AMP 
or the WAMP when they should not be, and reimbursement amounts for 
other codes would remain the same when, according to the statute, they 
may be lowered. 
The following example illustrates a case in which the method used to 
calculate volume-weighted ASPs and AMPs affects the outcome of the 
comparison between the ASP and the AMP. In this example, CMSs 
calculation results in a volume-weighted ASP of $1.20 and a volume-
weighted AMP of $1.10 for a given HCPCS code, while OIGs calculation 
results in a volume-weighted ASP of $1.17 and a volume-weighted AMP of 
$1.15 for that same HCPCS code. According to CMSs calculation, the ASP 
exceeds the AMP by 9 percent, which meets the 5-percent threshold 
specified in the Act. The reimbursement amount for this drug would then 
be eligible to be lowered to 103 percent of the AMP, or $1.13. However, 
according to OIGs calculation, the ASP exceeds the AMP by only 
2 percent, which does not meet the 5-percent threshold. Using OIGs 
calculation, the reimbursement for this HCPCS code would not be lowered. 
OEI-03-05-00310  CALCULATION OF VOLUME-WEIGHTED AVERAGE SALES PRICE  10  EEEER XXXXE EEEEC CCCCO UUUUM TTTTM IIIIEVVVVNEEEED     ASSSS TUUUU IMMMMO MMMMN AAAA RRRR YYYY
  R E C O M M E N D A T I O N  

Volume-weighted ASPs form the basis on which providers are 
reimbursed for most Part B drugs.  Therefore, any inaccuracies in these 
amounts have significant implications for the Medicare program, its 
health care providers, and its beneficiaries.  We believe that CMSs 
method for calculating volume-weighted ASPs is incorrect, and that the 
incorrect calculation can produce improper reimbursement amounts. 
Although we identified many HCPCS codes for which reimbursement 
was too high in the first quarter of 2005, we also found a number of 
HCPCS codes for which reimbursement was too low.  Moreover, the 
ratio between codes with reimbursements that are too high and those 
with reimbursements that are too low may periodically fluctuate given 
that the ASP data change from quarter to quarter.   
Furthermore, CMSs incorrect calculation has implications for future 
adjustments to reimbursement amounts based on OIG pricing 
comparisons mandated by the MMA.  It is therefore critical that the 
calculation of volume-weighted ASPs be performed correctly for all 
HCPCS codes. 
CMS Should Change its Method for Calculating Volume-Weighted ASPs 
We propose that CMS adopt an alternate equation, which uses billing 
units consistently and produces a volume-weighted ASP that is both 
mathematically correct and consistent with the results of the calculation 
set forth in section 1847A(b)(3) of the Act.   
AGENCY COMMENTS 
CMS indicated that it will consider the reports findings in its ongoing 
efforts to enhance implementation of the new ASP payment 
methodology.  CMS also stated that it presented the current ASP 
calculation in proposed rule 70 Fed. Reg. 45764, 45844 (August 8, 2005) 
and received public comments on its approach.  As CMS gains more 
experience with the ASP data, and as more information becomes 
available, CMS stated that it may consider altering the ASP 
methodology.   
The full text of CMSs comments can be found in Appendix E. 
OFFICE OF INSPECTOR GENERAL RESPONSE 
We continue to believe that CMS is calculating volume-weighted ASP 
incorrectly, and that this incorrect calculation results in reimbursement 
amounts that are inaccurate and inconsistent with the ASP payment 
methodology set forth in section 1847A(b)(3) of the Act.  According to 
  OEI-03-05-00310  CALCULATION OF VOLUME -WEIGHTED AVERAGE SALES PRICE  11  R E C O M M E N D A T I O N  
our analysis of prices from the first quarter of 2005, the net effect of 
inaccurate payments is a loss for the Medicare Trust Fund. 
OIGs concerns about the ASP calculation were echoed in the comments 
CMS received on proposed rule 70 Fed. Reg. 45764, 45844 (August 8, 
2005).  In response to the proposed rule, several manufacturers or their 
representatives noted that products are available in different package 
sizes and that a billing code may encompass multiple NDCs; therefore, 
weighting the ASP payment amount by NDCs sold does not reflect the 
true weighted average price per billing unit.  These commenters 
suggested that CMS revise its calculation so that the payment limit is 
based on the weighted ASP of the number of billing units sold rather 
than the number of NDCs sold.  Commenters on the proposed rule 
recognized that such a change could result in an increase or decrease to 
the reimbursement amount, but recommended that the calculation be 
altered nonetheless. 
We look forward to receiving CMSs comments on this final report. 
  OEI-03-05-00310  CALCULATION OF VOLUME-WEIGHTED AVERAGE SALES PRICE  12  A P P E N D I X ~ A  
  AA PP PP EE NN DD II XX    ~~    AA   
1.  The Equation Used by CMS to Calculate a Volume-Weighted ASP  
In the following equation, a unit is defined as the entire amount of the drug 
contained in the NDC: 
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 
2.  The Equation Used by OIG to Calculate a Volume-Weighted ASP  
We suggest that CMSs calculation should be modified by multiplying the number of 
NDCs sold by the number of billing units in the NDC in both the numerator and 
denominator of the equation: 
ASP for NDC  * Number of NDCs Sold * Billing Units in NDC 
Volume-Weighted ASP  Sum of 
Billing Units in NDC 
for the Billing Unit of  
= 
HCPCS Code 
Sum of   (Number of NDCs Sold * Billing Units in NDC) 
However, the terms Billing Units in NDC in the numerator of the equation cancel 
each other out: 
ASP for NDC  * Number of NDCs Sold * Billing Units in NDC 
Volume-Weighted ASP  Sum of 
Billing Units in NDC 
for the Billing Unit of  
= 
HCPCS Code 
Sum of  (Number of NDCs Sold * Billing Units in NDC) 
Therefore, OIGs equation is written in the following way: 
Volume-Weighted ASP  Sum of (ASP for NDC * Number of NDCs Sold) 
for the Billing Unit of   = 
 HCPCS Code 
Sum of  (Number of NDCs Sold * Billing Units in NDC) 
  OEI-03-05-00310  CALCULATION OF VOLUME-WEIGHTED AVERAGE SALES PRICE  13    A P P E N D I X   ~   B  
Table 1: Codes for Which CMSs Reimbursement Amount Exceeded         
OIGs Reimbursement Amount 
Estimated Monetary 
CMS's  OIG's  Difference  % Difference 
HCPCS  Impact of Correcting 
Reimbursement  Reimbursement  Between  Between 
Code  CMSs Calculation 
Amount  Amount  CMS and OIG  CMS and OIG 
(Gain to Medicare) 
J9217  $253.13  $230.09  $23.04  10.01%  $32,374,264.32 
J2275  $11.75  $4.88  $6.87  140.78%  $16,556,926.71 
Q0136  $10.18  $10.07  $0.11  1.09%  $9,324,462.07 
J7317  $110.27  $101.03  $9.24  9.15%  $5,975,905.32 
J9202  $189.79  $184.64  $5.15  2.79%  $5,013,185.10 
J1260  $6.61  $5.78  $0.83  14.36%  $4,859,645.85 
J1563  $56.72  $55.57  $1.15  2.07%  $4,688,351.05 
J2790  $102.36  $97.93  $4.43  4.52%  $4,108,156.07 
J1626  $7.09  $6.57  $0.52  7.91%  $2,601,538.16 
J7644  $0.29  $0.28  $0.01  3.57%  $2,137,831.40 
J1100  $0.14  $0.03  $0.11  366.67%  $2,038,162.17 
J7506  $0.22  $0.03  $0.19  633.33%  $1,694,987.15 
J2353  $85.39  $82.91  $2.48  2.99%  $1,630,845.52 
J3420  $0.47  $0.11  $0.36  327.27%  $1,465,893.00 
J9045  $125.47  $124.72  $0.75  0.60%  $1,441,580.25 
J9390  $69.09  $65.55  $3.54  5.40%  $1,324,887.48 
J1030  $5.36  $4.70  $0.66  14.04%  $1,324,384.38 
J1642  $0.07  $0.02  $0.05  250.00%  $1,082,555.20 
J1040  $9.75  $9.20  $0.55  5.98%  $982,224.10 
J3301  $1.32  $1.19  $0.13  10.92%  $952,077.49 
J1080  $12.62  $9.01  $3.61  40.07%  $933,574.88 
J1170  $1.71  $1.39  $0.32  23.02%  $825,428.80 
J0150  $31.07  $27.74  $3.33  12.00%  $804,461.40 
J7507  $3.31  $3.29  $0.02  0.61%  $739,314.16 
J2270  $1.86  $0.56  $1.30  232.14%  $691,308.80 
J1564  $0.57  $0.55  $0.02  3.64%  $671,911.78 
J1245  $1.93  $1.49  $0.44  29.53%  $569,168.60 
J1325  $12.16  $11.91  $0.25  2.10%  $523,334.75 
J9190  $1.68  $1.43  $0.25  17.48%  $437,058.50 
J2271  $5.07  $2.60  $2.47  95.00%  $424,229.91 
J0880  $17.72  $17.71  $0.01  0.06%  $408,226.02 
J1550  $100.02  $94.54  $5.48  5.80%  $395,721.76 
J0256  $3.28  $3.08  $0.20  6.49%  $386,787.60 
J0475  $180.49  $176.03  $4.46  2.53%  $382,346.88 
J1250  $5.11  $3.69  $1.42  38.48%  $348,010.76 
J0152  $70.00  $69.75  $0.25  0.36%  $344,831.75 
J7608  $2.30  $1.73  $0.57  32.95%  $299,276.22 
J0640  $1.30  $1.22  $0.08  6.56%  $287,072.72 
J2912  $0.15  $0.03  $0.12  400.00%  $276,065.04 
J9000  $4.25  $3.92  $0.33  8.42%  $265,254.99 
J9265  $15.85  $15.72  $0.13  0.83%  $243,959.95 
J0895  $15.67  $15.40  $0.27  1.75%  $182,897.19 
  OEI-03-05-00310  CALCULATION OF VOLUME -WEIGHTED AVERAGE SALES PRICE  14  A P P E N D I X ~ B  
Table 1: Codes for Which CMSs Reimbursement Amount Exceeded         
OIGs Reimbursement Amount 
Estimated Monetary 
CMS's  OIG's  Difference  % Difference 
HCPCS  Impact of Correcting 
Reimbursement  Reimbursement  Between  Between 
Code  CMSs Calculation 
Amount  Amount  CMS and OIG  CMS and OIG 
(Gain to Medicare) 
J2260  $4.77  $4.49  $0.28  6.24%  $173,673.64 
Q0179  $30.86  $28.92  $1.94  6.71%  $159,836.60 
J1885  $0.64  $0.50  $0.14  28.00%  $158,952.64 
J9214  $13.12  $13.06  $0.06  0.46%  $136,586.58 
J7669  $0.26  $0.25  $0.01  4.00%  $135,115.32 
J2997  $30.15  $27.10  $3.05  11.25%  $125,806.40 
J1580  $1.44  $0.52  $0.92  176.92%  $124,395.04 
J3303  $1.76  $1.37  $0.39  28.47%  $124,372.17 
J9260  $2.16  $1.53  $0.63  41.18%  $109,302.48 
Q0187  $1,043.05  $1,037.96  $5.09  0.49%  $103,820.73 
J1745  $53.08  $53.07  $0.01  0.02%  $93,175.94 
J2175  $1.37  $0.85  $0.52  61.18%  $91,967.72 
J1950  $445.11  $429.96  $15.15  3.52%  $78,295.20 
J1644  $0.10  $0.04  $0.06  150.00%  $75,384.24 
J2300  $1.33  $0.54  $0.79  146.30%  $73,007.85 
J2250  $0.48  $0.29  $0.19  65.52%  $67,366.02 
J2820  $21.67  $21.59  $0.08  0.37%  $58,779.84 
J3010  $0.27  $0.24  $0.03  12.50%  $56,022.66 
J9090  $13.91  $11.91  $2.00  16.79%  $54,766.00 
J2355  $243.35  $241.67  $1.68  0.70%  $46,045.44 
J1200  $0.94  $0.88  $0.06  6.82%  $43,953.60 
J3370  $2.42  $2.27  $0.15  6.61%  $42,812.10 
J0280  $0.50  $0.35  $0.15  42.86%  $41,536.95 
J1817  $2.18  $2.15  $0.03  1.40%  $39,502.35 
J3410  $0.35  $0.08  $0.27  337.50%  $37,937.43 
J0698  $5.02  $4.32  $0.70  16.20%  $37,765.00 
J9062  $18.37  $17.94  $0.43  2.40%  $36,858.31 
J7060  $0.79  $0.69  $0.10  14.49%  $35,240.00 
J7051  $0.01  $0.00  $0.01  N/A  $34,727.40 
J1940  $0.49  $0.35  $0.14  40.00%  $33,559.82 
J2010  $3.48  $3.33  $0.15  4.50%  $31,658.10 
J3480  $0.08  $0.04  $0.04  100.00%  $29,124.64 
J9182  $4.51  $4.35  $0.16  3.68%  $28,641.60 
J7070  $2.73  $2.22  $0.51  22.97%  $28,536.54 
J2060  $1.27  $0.98  $0.29  29.59%  $27,982.97 
J9100  $1.68  $1.12  $0.56  50.00%  $27,009.36 
Q0180  $47.72  $43.33  $4.39  10.13%  $26,620.96 
J2150  $1.02  $0.75  $0.27  36.00%  $26,580.42 
J1631  $5.80  $5.49  $0.31  5.65%  $26,469.35 
J2550  $2.15  $2.05  $0.10  4.88%  $24,214.60 
J9001  $356.35  $356.13  $0.22  0.06%  $24,175.80 
J0970  $29.67  $28.81  $0.86  2.99%  $22,988.66 
J9110  $8.38  $5.64  $2.74  48.58%  $19,253.98 
J9250  $0.20  $0.17  $0.03  17.65%  $18,879.24 
  OEI-03-05-00310  CALCULATION OF VOLUME -WEIGHTED AVERAGE SALES PRICE  15  A P P E N D I X ~ B  
Table 1: Codes for Which CMSs Reimbursement Amount Exceeded         
OIGs Reimbursement Amount 
Estimated Monetary 
CMS's  OIG's  Difference  % Difference 
HCPCS  Impact of Correcting 
Reimbursement  Reimbursement  Between  Between 
Code  CMSs Calculation 
Amount  Amount  CMS and OIG  CMS and OIG 
(Gain to Medicare) 
J7192  $0.92  $0.91  $0.01  1.10%  $18,782.04 
Q0166  $32.54  $30.80  $1.74  5.65%  $17,810.64 
J0690  $0.28  $0.16  $0.12  75.00%  $17,532.00 
J9181  $0.45  $0.43  $0.02  4.65%  $15,624.82 
J9070  $2.34  $2.27  $0.07  3.08%  $14,788.69 
J0460  $0.26  $0.17  $0.09  52.94%  $14,714.28 
J9213  $30.84  $30.31  $0.53  1.75%  $14,446.74 
J0670  $1.60  $1.49  $0.11  7.38%  $14,305.17 
J7130  $1.25  $0.02  $1.23  6150.00%  $13,975.26 
J7042  $0.14  $0.06  $0.08  133.33%  $13,844.48 
J9140  $11.25  $10.67  $0.58  5.44%  $13,735.56 
J0595  $1.82  $1.22  $0.60  49.18%  $13,224.00 
90703  $14.53  $14.33  $0.20  1.40%  $12,742.60 
J9091  $23.43  $22.69  $0.74  3.26%  $12,601.46 
J1645  $9.92  $9.60  $0.32  3.33%  $12,446.08 
J0800  $93.71  $93.70  $0.01  0.01%  $12,271.37 
J3315  $180.93  $176.24  $4.69  2.66%  $11,274.76 
J9360  $0.96  $0.87  $0.09  10.34%  $10,862.55 
J2930  $2.62  $2.58  $0.04  1.55%  $10,626.68 
J7030  $0.10  $0.08  $0.02  25.00%  $10,563.68 
J2360  $15.95  $15.12  $0.83  5.49%  $10,541.00 
J9130  $5.29  $4.98  $0.31  6.22%  $9,850.87 
J7040  $0.05  $0.04  $0.01  25.00%  $8,872.26 
J0215  $26.65  $26.62  $0.03  0.11%  $8,430.90 
J9060  $4.96  $4.94  $0.02  0.40%  $6,431.84 
J1390  $14.83  $14.41  $0.42  2.91%  $6,092.52 
J3360  $0.56  $0.42  $0.14  33.33%  $5,434.10 
Q4076  $0.72  $0.35  $0.37  105.71%  $5,375.36 
J9150  $27.42  $24.38  $3.04  12.47%  $5,192.32 
J1610  $55.17  $54.65  $0.52  0.95%  $2,730.00 
J9375  $7.00  $6.93  $0.07  1.01%  $2,728.25 
Q3025  $85.18  $85.17  $0.01  0.01%  $2,646.79 
J9092  $46.86  $45.38  $1.48  3.26%  $2,641.80 
J0637  $31.88  $31.79  $0.09  0.28%  $2,641.23 
J3265  $2.28  $2.00  $0.28  14.00%  $2,586.36 
J1190  $211.38  $211.07  $0.31  0.15%  $2,553.47 
J9080  $4.69  $4.54  $0.15  3.30%  $2,511.45 
J2510  $8.28  $8.02  $0.26  3.24%  $2,452.58 
Q0168  $8.31  $8.17  $0.14  1.71%  $2,396.66 
J1470  $20.00  $18.91  $1.09  5.76%  $2,389.28 
J9017  $33.30  $33.29  $0.01  0.03%  $2,339.49 
J2400  $16.52  $16.26  $0.26  1.60%  $2,245.36 
J1560  $100.02  $94.54  $5.48  5.80%  $2,076.92 
J2540  $1.00  $0.54  $0.46  85.19%  $2,018.94 
  OEI-03-05-00310  CALCULATION OF VOLUME -WEIGHTED AVERAGE SALES PRICE  16  A P P E N D I X ~ B  
Table 1: Codes for Which CMSs Reimbursement Amount Exceeded         
OIGs Reimbursement Amount 
Estimated Monetary 
CMS's  OIG's  Difference  % Difference 
HCPCS  Impact of Correcting 
Reimbursement  Reimbursement  Between  Between 
Code  CMSs Calculation 
Amount  Amount  CMS and OIG  CMS and OIG 
(Gain to Medicare) 
J9370  $3.50  $3.47  $0.03  0.86%  $2,014.14 
90632  $44.43  $42.98  $1.45  3.37%  $1,771.90 
J2354  $4.67  $4.61  $0.06  1.30%  $1,770.66 
J0692  $6.89  $6.87  $0.02  0.29%  $1,682.20 
J1490  $40.01  $37.82  $2.19  5.79%  $1,600.89 
J1500  $50.01  $47.28  $2.73  5.77%  $1,490.58 
J0270  $1.82  $1.22  $0.60  49.18%  $1,281.60 
J0697  $4.35  $4.22  $0.13  3.08%  $1,248.13 
J0610  $0.05  $0.04  $0.01  25.00%  $1,243.90 
J0500  $13.03  $12.70  $0.33  2.60%  $1,220.01 
J0694  $11.90  $11.64  $0.26  2.23%  $1,193.14 
J0170  $0.29  $0.27  $0.02  7.41%  $1,158.54 
90718  $9.25  $9.24  $0.01  0.11%  $1,107.64 
J1160  $3.04  $1.51  $1.53  101.32%  $962.37 
J1956  $7.64  $7.61  $0.03  0.39%  $879.75 
J3105  $12.66  $12.40  $0.26  2.10%  $812.76 
J7120  $0.76  $0.75  $0.01  1.33%  $776.54 
J0743  $11.72  $11.64  $0.08  0.69%  $776.48 
J2765  $0.45  $0.43  $0.02  4.65%  $757.36 
J2680  $1.14  $1.13  $0.01  0.88%  $716.92 
J2700  $1.61  $1.57  $0.04  2.55%  $662.08 
J2020  $23.76  $23.68  $0.08  0.34%  $499.04 
J2810  $0.38  $0.30  $0.08  26.67%  $495.60 
J1720  $1.81  $1.80  $0.01  0.56%  $450.14 
J0295  $6.67  $6.61  $0.06  0.91%  $438.24 
J0290  $0.21  $0.20  $0.01  5.00%  $427.37 
J1600  $11.30  $11.28  $0.02  0.18%  $378.92 
J1460  $10.00  $9.46  $0.54  5.71%  $331.56 
J1480  $30.00  $28.37  $1.63  5.75%  $324.37 
J0540  $23.02  $23.01  $0.01  0.04%  $245.49 
J1530  $80.02  $75.63  $4.39  5.80%  $237.06 
J0744  $8.57  $8.47  $0.10  1.18%  $224.80 
J0282  $0.38  $0.28  $0.10  35.71%  $219.40 
J1455  $10.63  $10.62  $0.01  0.09%  $213.90 
J1327  $12.40  $11.90  $0.50  4.20%  $184.00 
J1510  $60.05  $56.73  $3.32  5.85%  $169.32 
J3230  $2.39  $2.22  $0.17  7.66%  $151.64 
J2795  $0.08  $0.07  $0.01  14.29%  $148.49 
J9218  $13.49  $13.15  $0.34  2.59%  $146.54 
J2560  $3.17  $2.52  $0.65  25.79%  $101.40 
J8530  $1.02  $1.00  $0.02  2.00%  $99.72 
90375  $62.06  $61.86  $0.20  0.32%  $91.00 
J2993  $877.12  $873.92  $3.20  0.37%  $70.40 
J1540  $90.08  $85.12  $4.96  5.83%  $59.52 
  OEI-03-05-00310  CALCULATION OF VOLUME -WEIGHTED AVERAGE SALES PRICE  17  A P P E N D I X ~ B  
Table 1: Codes for Which CMSs Reimbursement Amount Exceeded         
OIGs Reimbursement Amount 
Estimated Monetary 
CMS's  OIG's  Difference  % Difference 
HCPCS  Impact of Correcting 
Reimbursement  Reimbursement  Between  Between 
Code  CMSs Calculation 
Amount  Amount  CMS and OIG  CMS and OIG 
(Gain to Medicare) 
J1815  $0.22  $0.21  $0.01  4.76%  $41.47 
J1165  $0.61  $0.54  $0.07  12.96%  $39.13 
J9380  $17.50  $17.34  $0.16  0.92%  $38.72 
J1955  $14.65  $14.10  $0.55  3.90%  $30.80 
J1520  $69.96  $66.14  $3.82  5.78%  $30.56 
J0456  $23.56  $23.55  $0.01  0.04%  $26.78 
Q0163  $0.03  $0.02  $0.01  50.00%  $17.80 
Q2009  $5.10  $4.67  $0.43  9.21%  $17.63 
J0745  $0.49  $0.45  $0.04  8.89%  $16.36 
J8700  $7.17  $7.16  $0.01  0.14%  $14.25 
J2280  $3.77  $3.76  $0.01  0.27%  $13.60 
J2515  $1.85  $1.73  $0.12  6.94%  $11.64 
J0330  $0.10  $0.08  $0.02  25.00%  $9.08 
Q0178  $0.08  $0.07  $0.01  14.29%  $7.85 
Q0164  $0.06  $0.05  $0.01  20.00%  $7.14 
J2710  $0.06  $0.03  $0.03  100.00%  $6.87 
J8610  $0.21  $0.19  $0.02  10.53%  $5.08 
90633  $21.95  $21.42  $0.53  2.47%  $4.77 
J0706  $3.27  $3.26  $0.01  0.31%  $3.97 
J0360  $7.13  $7.12  $0.01  0.14%  $3.24 
90385  $25.77  $25.47  $0.30  1.18%  $2.10 
J0300  $2.47  $2.44  $0.03  1.23%  $0.90 
J0470  $18.62  $18.61  $0.01  0.05%  $0.88 
J3030  $49.03  $49.00  $0.03  0.06%  $0.12 
Q0172  $0.09  $0.08  $0.01  12.50%  $0.12 
J2940  $40.16  $40.15  $0.01  0.02%  $0.01 
90705  $13.68  $13.67  $0.01  0.07%  $0.00 
90707  $35.96  $35.94  $0.02  0.06%  $0.00 
90716  $63.23  $62.41  $0.82  1.31%  $0.00 
J2941  $42.38  $42.32  $0.06  0.14%  $0.00 
J7344  $59.63  $17.68  $41.95  237.27%  $0.00 
J7613  $0.07  $0.05  $0.02  40.00%  $0.00 
J7614  $1.28  $1.09  $0.19  17.43%  $0.00 
J7616  $2.60  $2.50  $0.10  4.00%  $0.00 
J9035  $57.08  $57.07  $0.01  0.02%  $0.00 
J9305  $40.54  $40.53  $0.01  0.02%  $0.00 
Q2019  $1,476.21  $1,468.31  $7.90  0.54%  $0.00 
J3246  $7.85  $7.77  $0.08  1.03%  Not Available
 Total  $115,221,345.93 
  OEI-03-05-00310  CALCULATION OF VOLUME -WEIGHTED AVERAGE SALES PRICE  18    A P P E N D I X   ~   C  
Table 2: Codes for Which CMSs Reimbursement Amount Was Less Than     
OIGs Reimbursement Amount 
Estimated Monetary 
CMS's  OIG's  Difference  % Difference 
HCPCS  Impact of Correcting 
Reimbursement  Reimbursement  Between CMS  Between 
Code  CMSs Calculation 
Amount  Amount  and OIG  CMS and OIG 
(Loss to Medicare) 
J2430  $59.06  $62.15  -$3.09  -4.97%  -$1,633,151.52 
J9170  $297.58  $298.75  -$1.17  -0.39%  -$1,014,778.44 
J0696  $6.57  $6.76  -$0.19  -2.81%  -$435,180.94 
J7517  $2.51  $2.52  -$0.01  -0.40%  -$422,437.93 
J9350  $739.69  $744.25  -$4.56  -0.61%  -$280,996.32 
J7502  $3.90  $3.94  -$0.04  -1.02%  -$257,177.92 
J7631  $0.10  $0.12  -$0.02  -16.67%  -$173,850.20 
J0585  $4.71  $4.72  -$0.01  -0.21%  -$126,373.93 
J9206  $125.58  $125.64  -$0.06  -0.05%  -$64,532.58 
J2405  $3.73  $3.74  -$0.01  -0.27%  -$46,285.91 
J9310  $442.01  $442.03  -$0.02  0.00%  -$27,610.78 
J9209  $16.69  $16.90  -$0.21  -1.24%  -$26,215.14 
J9208  $62.04  $62.91  -$0.87  -1.38%  -$23,229.87 
J2788  $24.47  $24.97  -$0.50  -2.00%  -$23,170.50 
J1450  $44.85  $49.11  -$4.26  -8.67%  -$23,110.50 
J2780  $0.93  $1.00  -$0.07  -7.00%  -$20,904.03 
J1650  $5.15  $5.19  -$0.04  -0.77%  -$18,403.48 
J0702  $4.51  $4.52  -$0.01  -0.22%  -$9,725.23 
J1750  $11.06  $11.07  -$0.01  -0.09%  -$8,312.74 
J9040  $55.01  $55.67  -$0.66  -1.19%  -$8,300.16 
J1440  $178.94  $178.95  -$0.01  -0.01%  -$6,536.72 
J9211  $317.27  $322.72  -$5.45  -1.69%  -$5,847.85 
J1630  $2.56  $3.07  -$0.51  -16.61%  -$5,755.35 
J1110  $28.75  $29.88  -$1.13  -3.78%  -$4,680.46 
J2001  $0.01  $0.02  -$0.01  -50.00%  -$2,641.37 
J0780  $3.01  $3.20  -$0.19  -5.94%  -$2,369.87 
J9340  $43.57  $43.79  -$0.22  -0.50%  -$1,818.08 
J9293  $321.80  $321.82  -$0.02  -0.01%  -$1,694.00 
J3260  $1.98  $2.00  -$0.02  -1.00%  -$1,234.42 
J1070  $4.91  $4.92  -$0.01  -0.20%  -$1,123.93 
J7682  $46.98  $46.99  -$0.01  -0.02%  -$906.43 
J2543  $4.59  $4.65  -$0.06  -1.29%  -$881.22 
J7509  $0.07  $0.08  -$0.01  -12.50%  -$874.54 
J1230  $3.28  $3.29  -$0.01  -0.30%  -$344.39 
J1590  $0.44  $0.45  -$0.01  -2.22%  -$254.53 
J1051  $4.89  $4.90  -$0.01  -0.20%  -$221.16 
J2440  $0.76  $0.84  -$0.08  -9.52%  -$178.56 
J1790  $1.02  $1.13  -$0.11  -9.73%  -$171.71 
  OEI-03-05-00310  CALCULATION OF VOLUME -WEIGHTED AVERAGE SALES PRICE  19  A P P E N D I X ~ C  
Table 2: Codes for Which CMSs Reimbursement Amount Was Less Than     
OIGs Reimbursement Amount 
Estimated Monetary 
CMS's  OIG's  Difference  % Difference 
HCPCS  Impact of Correcting 
Reimbursement  Reimbursement  Between CMS  Between 
Code  CMSs Calculation 
Amount  Amount  and OIG  CMS and OIG 
(Loss to Medicare) 
90371 
$113.57  $113.94  -$0.37  -0.32%  -$167.24 
J2370  $0.63  $0.75  -$0.12  -16.00%  -$111.48 
J2185  $3.40  $3.41  -$0.01  -0.29%  -$101.18 
J0715  $2.70  $2.73  -$0.03  -1.10%  -$95.70 
J0725  $2.58  $2.59  -$0.01  -0.39%  -$71.63 
J2320  $3.41  $3.43  -$0.02  -0.58%  -$47.96 
J9098  $350.45  $350.46  -$0.01  0.00%  -$27.69 
J1800  $5.10  $5.11  -$0.01  -0.20%  -$16.58 
J3305  $136.93  $136.94  -$0.01  -0.01%  -$10.44 
J1180  $4.00  $4.01  -$0.01  -0.25%  -$10.21 
90376  $66.31  $66.36  -$0.05  -0.08%  -$6.95 
J0720  $6.10  $6.11  -$0.01  -0.16%  -$5.57 
90700  $12.81  $12.96  -$0.15  -1.16%  -$2.40 
J2783  $107.01  $107.02  -$0.01  -0.01%  -$2.26 
Q2017  $263.67  $265.15  -$1.48  -0.56%  -$1.48 
J7110  $10.71  $10.72  -$0.01  -0.09%  -$0.72 
90585  $122.54  $122.55  -$0.01  -0.01%  -$0.10 
Q2007  $63.36  $63.37  -$0.01  -0.02%  -$0.02 
90396  $109.82  $109.83  -$0.01  -0.01%  -$0.01 
J0180  $121.12  $121.14  -$0.02  -0.02%  $0.00 
J7518  $2.42  $2.43  -$0.01  -0.41%  $0.00 
Q0171  $0.10  $0.11  -$0.01  -9.09%  $0.00 
Q0176  $0.26  $0.27  -$0.01  -3.70%  $0.00
 Total  -$4,681,962.33 
  OEI-03-05-00310  CALCULATION OF VOLUME -WEIGHTED AVERAGE SALES PRICE  20    A P P E N D I X   ~   D  
Table 3: Codes for Which CMSs Reimbursement Amount and OIGs Reimbursement 
Amount Were the Same 
CMS's  OIG's 
HCPCS 
Reimbursement  Reimbursement 
Code 
Amount  Amount 
Q2014  $8.77  $8.77
J2505  $2,273.93  $2,273.93 
J3487  $198.39  $198.39 
J9263  $8.24  $8.24 
J9201  $115.34  $115.34 
J7626  $4.03  $4.03 
J9219  $2,206.27  $2,206.27 
J7320  $200.15  $200.15 
J9355  $52.99  $52.99 
J1441  $282.41  $282.41 
Q0137  $3.54  $3.54 
J2792  $13.40  $13.40 
J7190  $0.52  $0.52 
J9395  $80.51  $80.51 
J9185  $272.09  $272.09 
J7520  $6.73  $6.73 
J1785  $3.91  $3.91 
Q4077  $54.02  $54.02 
J9031  $118.41  $118.41 
J0207  $417.56  $417.56 
J7515  $0.99  $0.99 
J7198  $1.09  $1.09 
J2324  $73.33  $73.33 
J7195  $0.84  $0.84 
J9010  $511.48  $511.48 
J7193  $0.75  $0.75 
J9015  $672.06  $672.06 
J9178  $25.41  $25.41 
J7050  $0.02  $0.02 
Q4054  $3.54  $3.54 
J9160  $1,205.53  $1,205.53 
J9291  $141.14  $141.14 
J0587  $7.76  $7.76 
Q2022  $0.72  $0.72 
J9268  $1,870.88  $1,870.88 
J9290  $65.91  $65.91 
J1756  $0.36  $0.36 
J7342  $15.32  $15.32 
J9096  $6.04  $6.04 
J7500  $0.19  $0.19 
J9300  $2,203.67  $2,203.67 
  OEI-03-05-00310  CALCULATION OF VOLUME -WEIGHTED AVERAGE SALES PRICE  21  A P P E N D I X ~ D  
Table 3: Codes for Which CMSs Reimbursement Amount and OIGs Reimbursement 
Amount Were the Same 
CMS's  OIG's 
HCPCS 
Reimbursement  Reimbursement 
Code 
Amount  Amount 
J9093  $0.60  $0.60
J2916  $4.83  $4.83 
J9065  $43.29  $43.29 
J7639  $16.93  $16.93 
J9095  $3.02  $3.02 
J3240  $699.60  $699.60 
J8521  $10.76  $10.76 
J0287  $11.94  $11.94 
J1020  $2.67  $2.67 
J7340  $26.51  $26.51 
J1335  $21.30  $21.30 
J0289  $20.38  $20.38 
J1212  $36.79  $36.79 
J9280  $23.38  $23.38 
J3130  $14.99  $14.99 
J9200  $71.39  $71.39 
J7308  $87.65  $87.65 
J1655  $2.60  $2.60 
J0205  $39.22  $39.22 
J0600  $39.74  $39.74 
J1670  $68.47  $68.47 
J0285  $29.84  $29.84 
J1570  $33.93  $33.93 
J9050  $139.10  $139.10 
J9097  $12.08  $12.08 
J9094  $1.21  $1.21 
J1410  $56.71  $56.71 
J9320  $153.82  $153.82 
J0550  $29.91  $29.91 
J0570  $30.41  $30.41 
J0740  $762.50  $762.50 
J0713  $3.74  $3.74 
J9600  $2,285.15  $2,285.15 
J7194  $0.49  $0.49 
J9245  $388.73  $388.73 
J0476  $67.55  $67.55 
90586  $118.41  $118.41 
J2920  $1.92  $1.92 
J1000  $5.02  $5.02 
90675  $115.02  $115.02 
Q4075  $0.03  $0.03 
J0850  $672.61  $672.61 
  OEI-03-05-00310  CALCULATION OF VOLUME -WEIGHTED AVERAGE SALES PRICE  22  A P P E N D I X ~ D  
Table 3: Codes for Which CMSs Reimbursement Amount and OIGs Reimbursement 
Amount Were the Same 
CMS's  OIG's 
HCPCS 
Reimbursement  Reimbursement 
Code 
Amount  Amount 
J3120  $7.49  $7.49
J0580  $60.28  $60.28 
J7513  $380.28  $380.28 
J3475  $0.01  $0.01 
J0530  $11.37  $11.37 
J3465  $4.55  $4.55 
J2760  $22.47  $22.47 
J2322  $13.86  $13.86 
Q0167  $4.00  $4.00 
J2545  $39.05  $39.05 
J2770  $103.25  $103.25 
J7511  $297.78  $297.78 
J9020  $54.52  $54.52 
J1438  $147.16  $147.16 
J0560  $17.29  $17.29 
J3415  $2.36  $2.36 
J2597  $2.47  $2.47 
J0770  $45.09  $45.09 
J0760  $4.07  $4.07 
J7525  $124.27  $124.27 
J3320  $28.65  $28.65 
Q0165  $0.04  $0.04 
J3250  $4.12  $4.12 
J9266  $1,459.51  $1,459.51 
J2321  $6.56  $6.56 
J9230  $10.45  $10.45 
J2501  $4.02  $4.02 
J0130  $431.24  $431.24 
J3100  $2,040.05  $2,040.05 
J1980  $4.71  $4.71 
J1652  $6.74  $6.74 
J1270  $2.80  $2.80 
J2730  $85.79  $85.79 
J1120  $12.70  $12.70 
J8520  $3.24  $3.24 
J9151  $55.99  $55.99 
J9120  $12.07  $12.07 
J7100  $14.05  $14.05 
J0630  $35.03  $35.03 
J0592  $0.82  $0.82 
J7501  $46.88  $46.88 
J1380  $11.36  $11.36 
  OEI-03-05-00310  CALCULATION OF VOLUME -WEIGHTED AVERAGE SALES PRICE  23  A P P E N D I X ~ D  
Table 3: Codes for Which CMSs Reimbursement Amount and OIGs Reimbursement 
Amount Were the Same 
CMS's  OIG's 
HCPCS 
Reimbursement  Reimbursement 
Code 
Amount  Amount 
J2675  $1.93  $1.93
J0636  $0.71  $0.71 
J7504  $283.59  $283.59 
J0210  $9.03  $9.03 
J7330  $16,284.90  $16,284.90 
J2690  $0.90  $0.90 
J0515  $3.40  $3.40 
J1835  $36.23  $36.23 
J7516  $20.59  $20.59 
J3364  $8.15  $8.15 
J3365  $407.54  $407.54 
J3486  $18.74  $18.74 
J3411  $0.58  $0.58 
J7310  $4,240.00  $4,240.00 
J0583  $0.15  $0.15 
J1742  $223.65  $223.65 
J1840  $0.23  $0.23 
J7505  $830.01  $830.01 
J2995  $76.32  $76.32 
J1240  $4.73  $4.73 
J1830  $80.53  $80.53 
J1364  $2.94  $2.94 
J2410  $2.29  $2.29 
J3485  $0.96  $0.96 
J1320  $1.79  $1.79 
J1730  $112.01  $112.01 
Q2012  $154.05  $154.05 
J8560  $31.03  $31.03 
J2210  $4.30  $4.30 
J2590  $1.04  $1.04 
J1595  $34.85  $34.85 
J0275  $20.75  $20.75 
Q2002  $2.98  $2.98 
Q0177  $0.07  $0.07 
J1205  $9.13  $9.13 
Q0170  $0.16  $0.16 
Q0169  $0.28  $0.28 
Q2021  $133.75  $133.75 
Q2006  $555.03  $555.03 
J2720  $0.36  $0.36 
Q0175  $0.21  $0.21 
90704  $17.81  $17.81 
  OEI-03-05-00310  CALCULATION OF VOLUME -WEIGHTED AVERAGE SALES PRICE  24  A P P E N D I X ~ D  
Table 3: Codes for Which CMSs Reimbursement Amount and OIGs Reimbursement 
Amount Were the Same 
CMS's  OIG's 
HCPCS 
Reimbursement  Reimbursement 
Code 
Amount  Amount 
90706  $14.98  $14.98
J0128  $68.62  $68.62 
J0135  $577.56  $577.56 
J0878  $0.28  $0.28 
J2357  $15.32  $15.32 
J2469  $18.22  $18.22 
J2794  $4.60  $4.60 
J3396  $8.99  $8.99 
J7611  $0.07  $0.07 
J7612  $0.87  $0.87 
J8501  $4.62  $4.62 
J8510  $1.91  $1.91 
J9041  $28.38  $28.38 
J9055  $49.64  $49.64 
J1457  $1.25  $1.25 
J1931  $22.74  $22.74 
J7674  $0.41  $0.41 
Q2003  $2.15  $2.15 
Q2008  $11.55  $11.55 
  OEI-03-05-00310  CALCULATION OF VOLUME -WEIGHTED AVERAGE SALES PRICE  25     A P P E N D I X   ~   E  

Comments from the Centers for Medicare & Medicaid Services 
  OEI-03-05-00310  CALCULATION OF VOLUME-WEIGHTED AVERAGE SALES PRICE  26    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 Linda M. Ragone, Deputy Regional Inspector 
General. Other principal Office of Evaluation and Inspections staff who 
contributed include: 
Lauren McNulty, Team Leader 
Linda Boone Abbott, Program Specialist 
  OEI-03-05-00310  CALCULATION OF VOLUME-WEIGHTED AVERAGE SALES PRICE  27