Department of Health and Human Services 

OFFICE OF 

INSPECTOR GENERAL 

JANET REHNQUIST 

Inspector General 

SEPTEMBER 2001 

OEI-03-01-00010 

Medicaid’s Use of Revised 

Average Wholesale Prices 
OFFICE OF INSPECTOR GENERAL 

The mission of the Office of Inspector General (OIG), as mandated by Public Law 95-452, is to 

protect the integrity of the Department of Health and Human Services programs as well as the 

health and welfare of beneficiaries served by them. This statutory mission is carried out through a 

nationwide program of audits, investigations, inspections, sanctions, and fraud alerts. The 

Inspector General informs the Secretary of program and management problems and recommends 

legislative, regulatory, and operational approaches to correct them. 

Office of Evaluation and Inspections 

The Office of Evaluation and Inspections (OEI) is one of several components of the Office of 

Inspector General. It conducts short-term management and program evaluations (called 

inspections) that focus on issues of concern to the Department, the Congress, and the public. The 

inspection reports provide findings and recommendations on the efficiency, vulnerability, and 

effectiveness of departmental programs. 

OEI's Philadelphia Regional Office prepared this report under the direction of Robert A. Vito, 

Regional Inspector General, and Linda M. Ragone, Deputy Regional Inspector General. Principal 

OEI staff included: 

REGION HEADQUARTERS 

David Tawes, Project Leader Linda Frisch, Program Specialist 

To obtain copies of this report, please call the Philadelphia Regional Office at (800) 531-9562. 

Reports are also available on the World Wide Web at our home page address: 

http://www.hhs.gov/oig/oei 
EXECUTIVE SUMMARY 

PURPOSE 

This report describes State Medicaid agencies’ use of revised average wholesale prices for 

certain prescription drugs. 

BACKGROUND 

Medicaid payments for prescription drugs totaled almost $12 billion in 1998, accounting 

for nearly 7 percent of all Medicaid expenditures. Most State Medicaid agencies 

reimburse pharmacies based on the average wholesale price of a drug less a discount 

ranging from 4 to 15 percent. States do not always use the same reimbursement for drugs 

administered directly by physicians. Drug manufacturers report average wholesale prices 

to companies such as First DataBank and Medical Economics. These companies compile 

pricing data for the pharmaceutical industry. 

Recently, a national investigation conducted by the United States Department of Justice 

and the National Association of Medicaid Fraud Control Units (NAMFCU) revealed that 

some drug manufacturers were reporting inflated average wholesale prices for certain 

products. As a result, the two entities collected actual wholesale pricing data for 

approximately 400 national drug codes representing 51 drugs. This data was provided to 

First DataBank, who calculated new average wholesale prices for the drugs, and 

subsequently made the revised prices available to State Medicaid programs. The 

NAMFCU strongly encouraged States to make use of the revised prices, and anticipated 

that their implementation would result in a significant reduction in Medicaid 

reimbursement for the drugs involved. 

We gathered information from Medicaid representatives in 48 States and the District of 

Columbia. We asked States about their drug reimbursement methodologies, whether or 

not they had implemented the revised average wholesale prices, and if they had any 

problems or concerns about these prices. We also asked States that had implemented the 

revised prices to provide cost-savings estimates, if available. 

FINDINGS 

Thirty States use at least some of the revised average wholesale prices when 

determining drug reimbursement amounts 

Thirty States have incorporated the revised prices into their drug reimbursement 

methodology in some manner. However, States vary considerably in their methods of 

Medicaid’s Use of Revised Average Wholesale Prices OEI-03-01-00010 
implementation. Of the 30 States that have adopted the revised prices, 9 States use them 

for both pharmacy drugs and physician-administered drugs. The remaining 21 States use 

the revised prices for pharmacy drugs only. 

States reported both advantages and disadvantages to using the revised prices 

Seven States expressed complete support of the efforts to revise drug prices. These States 

noted that reported average wholesale prices are often extremely inflated, and they 

welcomed the efforts to obtain more accurate prices. Seventeen States appreciated the 

intent of the revised prices, but questioned whether the effort was the best solution. 

Nearly all States reported that certain groups opposed the use of the revised average 

wholesale prices. Opposition came from a number of sources, including hemophilia 

groups, pharmacies, infusion providers, physicians, and drug manufacturers. 

States using the revised prices believe they will lead to short-term cost-savings, 

but are unsure of the long-term impact 

Of the 30 States who are currently using the revised prices, 24 believed the prices will 

result in short-term cost-savings. However, 20 of the 30 States either do not believe or 

are unsure that the new prices will lead to any long-term savings. Seven States provided 

cost-savings estimates, with annual savings ranging from $800,000 to $7 million. 

CONCLUSION 

Over the last several years, the OIG has produced a significant body of work that clearly 

demonstrates the inflated nature of reported average wholesale prices. Because most 

States base their reimbursement for drugs on average wholesale prices, this inflation has 

caused Medicaid to pay too much for certain products. Therefore, we commend any 

efforts to obtain more accurate pricing for the Medicaid program. 

This report shows that some States are benefitting from the revised average wholesale 

prices prompted by the actions of the Justice Department and the NAMFCU. However, 

States’ concerns about the revised prices indicate that attempting to lower reimbursement 

simply by further reducing average wholesale prices may not be an effective long-term 

solution. Therefore, we continue to believe that the current system’s reliance on reported 

average wholesale prices as a basis for drug reimbursement is fundamentally flawed. 

Agency Comments 

The CMS agreed with our conclusion that the reliance on reported average wholesale 

prices as a basis for drug reimbursement is problematic, and stated that they will continue 

to look for administrative and legislative solutions to this problem. In addition, the CMS 

made two technical comments concerning items in the draft report. We have addressed 

the technical comments in this final version of the report. 

Medicaid’s Use of Revised Average Wholesale Prices ii OEI-03-01-00010 
TABLE OF CONTENTS 

PAGE

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

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

FINDINGS

States’ Use of Revised Prices ............................................. 5

States’ Experiences with Revised Prices ..................................... 6

Potential Cost Savings of Revised Prices .................................... 7

CONCLUSION ............................................................ 9

APPENDICES

Use of Revised Average Wholesale Prices by State. ........................... 10

Centers for Medicare & Medicaid Services Comments ......................... 12

Medicaid’s Use of Revised Average Wholesale Prices iii OEI-03-01-00010 
INTRODUCTION 

PURPOSE 

This report describes State Medicaid agencies’ use of revised average wholesale prices for 

certain prescription drugs. 

BACKGROUND 

Congress created Medicaid in 1965 under Title XIX of the Social Security Act. Medicaid 

is a joint Federal and State program that provides medical assistance to individuals and 

families with low incomes and few resources. Individual States establish eligibility 

requirements, benefits packages, and payment rates for Medicaid under broad standards 

set by the Centers for Medicare & Medicaid Services (CMS). The Federal Government 

contributes between 50 and 83 percent of the Medicaid funding for each State. In 1998, 

Medicaid helped provide approximately 40 million people with medical assistance, at a 

cost of over $175 billion. 

Medicaid Coverage of Prescription Drugs 

Federal guidelines require States to provide certain benefits, such as hospital and physician 

services, to their Medicaid recipients. Each State also has the option of providing other 

Medicaid benefits, including prescription drugs. Currently, all 50 States and the District of 

Columbia offer prescription drug coverage for Medicaid recipients. Medicaid payments 

for prescription drugs totaled almost $12 billion in 1998, accounting for nearly 7 percent 

of all Medicaid expenditures. 

Most outpatient prescription drugs are covered by Medicaid. However, States often have 

different reimbursement methods for drugs obtained through pharmacies versus drugs 

administered in physicians’ offices. Drugs purchased from pharmacies are covered and 

reimbursed under States’ prescription drug programs. In contrast, drugs administered by 

physicians are usually reimbursed through the physician payment process, and not the 

prescription drug program. 

Pharmacies use national drug codes to identify and obtain reimbursement for drugs 

covered under a State’s prescription drug program. Each drug manufactured or 

distributed in the United States has a unique national drug code that identifies the 

manufacturer of the drug, the product dosage form, and the package size. Physicians, 

however, often bill Medicaid for drugs on the HCFA 1500 claim form, which does not 

specifically request national drug code information. On the HCFA 1500 form, drugs are 

identified by codes in the HCFA Common Procedure Coding System, hereinafter referred 

Medicaid’s Use of Revised Average Wholesale Prices 1 OEI-03-01-00010 
to as procedure codes. Procedure codes define the type of drug and the dosage amount, 

but not the specific drug product or its manufacturer. 

Medicaid Drug Reimbursement Methodology 

Each Medicaid agency is required to submit a State plan to CMS describing its payment 

methodology for covered drugs. Federal regulations require that each State’s 

reimbursement for a drug not exceed, in the aggregate, the lower of its estimated 

acquisition cost or the providers’ usual and customary charge to the public for the drug. 

However, CMS allows States flexibility in defining estimated acquisition cost. 

When reimbursing for a pharmacy drug, 43 State Medicaid agencies base their calculation 

of estimated acquisition cost on the drug’s average wholesale price discounted by 4 to 17 

percent. Four other States use wholesale acquisition cost plus 5 to 11 percent when 

calculating estimated acquisition cost. Three States use a combination of both methods. 

Drug manufacturers report average wholesale prices to companies such as First DataBank 

and Medical Economics. These companies compile pricing data for the pharmaceutical 

industry. This pricing data is usually reported using national drug codes rather than 

procedure codes. 

For certain pharmacy drugs, States use the Federal Upper Limit and the State Maximum 

Allowable Cost programs in determining reimbursement amounts. The CMS has 

established Federal upper limit payment amounts for over 200 drugs. In addition, more 

than half of States have implemented a maximum allowable cost program to limit payment 

amounts for certain prescription drugs. States vary considerably in the method by which 

this maximum allowable cost is calculated. A small number of States use other pricing 

mechanisms for specific categories of drugs, such as blood factors used in the treatment of 

hemophilia. These States may obtain prices directly from manufacturers, require invoices 

from providers that show actual acquisition costs, or calculate reimbursement through 

various other methods. 

Many States reimburse physician-administered drugs differently than pharmacy drugs. 

The majority of States still base reimbursement for physician-administered drugs on 

average wholesale price. However, some States discount average wholesale prices by 

different amounts for physician drugs compared to pharmacy drugs, while other States 

subtract no discount at all. Many physician-administered drugs are billed using procedure 

codes that do not have corresponding average wholesale prices. Therefore, calculating 

reimbursement amounts for physician-administered drugs can be more complicated than 

for pharmacy drugs. 

Overall, most Medicaid States reimburse for drugs purchased from a pharmacy at the 

lower of the discounted average wholesale price, the Federal upper limit, the State 

maximum allowable cost, or the provider’s usual and customary charge. States often 

reimburse for physician-administered drugs in a different manner, though most still use 

average wholesale price as the primary basis for determining reimbursement. 

Medicaid’s Use of Revised Average Wholesale Prices 2 OEI-03-01-00010 
Revised Drug Prices for Medicaid 

A recent investigation conducted by the United States Department of Justice and the 

National Association of Medicaid Fraud Control Units (NAMFCU) revealed that some 

drug manufacturers were reporting inflated average wholesale prices for certain products. 

The investigation suggested that these inflated prices have caused the Medicaid program 

to overpay substantially for these drugs. As a result, the Justice Department and the 

NAMFCU collected actual average wholesale pricing data for approximately 400 of the 

more than 50,000 national drug codes presently in use. These 400 codes represent 51 

injectable, infusion, and inhalation drugs. The data was gathered from several wholesale 

drug catalogs. 

In a February 2000 letter to State Medicaid pharmacy directors, the NAMFCU stated that 

the pricing data had been given to First DataBank, the company that provides average 

pricing information to nearly all of the State Medicaid agencies. First DataBank agreed to 

use this data to calculate revised average wholesale prices for the 51 drugs, and to 

subsequently make the revised prices available to the States. In encouraging the States to 

take advantage of these revised prices, the NAMFCU wrote: 

This revised procedure does not change the terms of the company’s [First 

DataBank’s] contract with your State, but merely provides an improved 

means for First DataBank to provide more accurate information to the 

States. More importantly, in view of the Medicaid program’s legal 

obligation to reimburse true provider acquisition costs, such an effort by 

the States to ensure that payment is based on actual prices is mandatory. 

According to the letter, Medicaid agencies may make changes to the list of national drug

codes with revised prices. First DataBank agreed that every six months it would collect

information from wholesale catalogs when updating prices for the approximately 400

national drug codes. The NAMFCU anticipated that the use of the revised prices would

result in a significant reduction in reimbursement for the drugs involved.

First DataBank began reporting the revised average wholesale prices to States on 

May 1, 2000. However, some States did not wish to use the revised prices, and requested

that First DataBank continue to supply the original prices instead. 

METHODOLOGY 

We reviewed relevant information about the Medicaid program, specifically materials 

relating to Medicaid drug reimbursement. In addition, we obtained correspondence from 

First DataBank and the NAMFCU concerning the implementation of the revised average 

wholesale prices. 

Medicaid’s Use of Revised Average Wholesale Prices 3 OEI-03-01-00010 
Data Collection and Analysis 

We conducted telephone interviews with Medicaid representatives in 48 States and the 

District of Columbia, hereinafter referred to as a State. Whenever possible, the interview 

was conducted with the States’ drug program administrator. We did not speak with 

Medicaid staff from Arizona because the State’s drug benefit is administered completely 

through managed care organizations and not the traditional fee-for-service system. 

Representatives of Maine’s Medicaid program did not respond to our request for an 

interview. In this report, we use the word “State” to denote both a “State Medicaid 

agency” and “State Medicaid agency representative.” 

Before contacting the States, we developed questions about the revised average wholesale 

prices with the assistance of CMS staff and two State drug program administrators. We 

asked States about their drug reimbursement methodologies, whether or not they had 

implemented the revised average wholesale prices, and if they had any problems or 

concerns about these prices. We also asked States that had implemented the revised 

prices to provide cost-savings estimates. However, we did not validate the cost-savings 

estimates reported by States. We also gave each State an opportunity to discuss any other 

issues they felt needed to be addressed concerning the revised average wholesale prices. 

We collected this data between January and March 2001. 

Medicaid’s Use of Revised Average Wholesale Prices 4 OEI-03-01-00010 
FINDINGS 

Thirty States use at least some of the revised average 

wholesale prices when determining drug reimbursement 

amounts 

Thirty States have incorporated the revised prices into their drug reimbursement 

methodology in some manner. However, States vary considerably in the methods of 

implementation. For the most part, States use these prices as one of the factors in 

calculating a drug’s reimbursement amount. States continue to use Federal upper limits, 

State maximum allowable costs, and various other pricing methods in combination with 

the revised average wholesale prices calculated by First DataBank. 

Because the revised average wholesale prices are based on national drug codes, many 

States have found it difficult to use them for physician-administered drugs, which are 

usually reimbursed by procedure code. Of the 30 States that have adopted the revised 

prices, nine States use them for both pharmacy drugs and physician-administered drugs. 

The remaining 21 States use the revised prices for pharmacy drugs only. A table outlining 

how each State uses the revised prices is provided in appendix A. 

Some States do not use the revised prices for certain drug products. For example, two 

States discontinued using the revised prices for blood factors. Three other States that 

base reimbursement primarily on wholesale acquisition cost or direct pricing use the 

revised prices only when these other prices are not available. One State cannot use the 

revised average wholesale prices for certain claims because First DataBank refused to 

provide the revised prices to one of the State’s contractors. 

Eleven States do not take a percentage discount off the revised average 

wholesale prices 

When determining reimbursement, States generally subtract a percentage discount from 

the drug’s average wholesale price. However, 11 of the 30 States that use the revised 

prices do not subtract this percentage discount when paying for drugs that have revised 

prices. Several States reported that the revised average wholesale prices are closer to a 

true acquisition cost; therefore, subtracting a percentage discount may actually make the 

reimbursement amount fall below a provider’s acquisition cost. They remarked that if 

providers were reimbursed below cost, they would simply stop providing these drugs, 

which could limit a patient’s access to care. 

Several other States have considered eliminating the percentage discount when 

determining reimbursement for the drugs with revised prices. However, these States are 

Medicaid’s Use of Revised Average Wholesale Prices 5 OEI-03-01-00010 
unsure they have the authority to change their reimbursement methodology for this small 

group of drugs without undertaking significant administrative and/or legislative actions. 

States reported both advantages and disadvantages to using 

the revised prices 

Some States were completely supportive of the efforts to revise prices 

Seven States reported only positive opinions about the revised prices. These States noted 

that reported average wholesale prices are often extremely inflated, and they welcomed 

the Justice Department’s and NAMFCU’s efforts to obtain more accurate prices. One 

State pharmacy director said, “This kind of pricing information should be aggressively 

pursued by First DataBank, the OIG, and HCFA.” Two other pharmacy directors hoped 

that the revised pricing would be expanded to even more drugs. 

Other States appreciated the intent of the revised prices, but questioned whether 

the effort was the best solution 

Seventeen States supported the efforts to revise prices, but had concerns with the specific 

actions taken. Four of these States believed that attempts to reduce excessive 

reimbursement for prescription drugs should not be based on determining more accurate 

average wholesale prices. According to these States, basing payment on the actual 

acquisition cost of a drug or on the average manufacturer’s price reported to CMS under 

the Medicaid Drug Rebate Program is a much more effective solution. The other 13 

States did not report problems with the use of average wholesale prices in general. 

Rather, they cited concerns about the particular drugs included in the revisions and 

questioned how the revised prices would be updated. 

Several States noted that the drugs chosen for pricing revisions were mainly infusion and 

injectable products that did not amount to a significant portion of Medicaid drug spending. 

One respondent termed these drugs “small potatoes,” and felt that price reductions should 

have been targeted to a different class of products such as oral tablets. Others noted that 

basing the revisions on specific national drug codes rather than entire drug classes could 

potentially limit the effectiveness of the revisions. 

States also expressed concern about the process of updating the revised prices. Even 

though First DataBank is required by its agreement with the NAMFCU to collect updated 

prices for these drugs, some States reported that First DataBank expressed little interest in 

updating the revised prices. According to these States, First DataBank only planned on 

reporting revised prices based on what the Justice Department and the NAMFCU 

provided them. Meanwhile, States were unsure if the Justice Department and the 

NAMFCU were planning to provide updated pricing information to First DataBank and/or 

add any new national drug codes to the pricing revisions. 

Medicaid’s Use of Revised Average Wholesale Prices 6 OEI-03-01-00010 
Some States felt these problems were never addressed because the Justice Department and 

the NAMFCU sought little or no input from State drug program administrators. 

According to one State, many of the concerns States have with the revised prices could 

have been avoided if the drug program administrators had been included in the 

decision-making process. 

States reported that certain groups opposed the use of the revised average 

wholesale prices 

Forty-three States reported receiving complaints about the revised prices. These 

complaints were from a number of sources, including hemophilia groups, pharmacies, 

infusion providers, physicians, and drug manufacturers. All asserted that the revised 

prices were too low. Some hemophilia providers claimed that they would be unable to 

continue treating Medicaid recipients unless the prices for blood factors were raised. 

These complaints were instrumental in two States’ decisions to discontinue the use of the 

revised prices for blood-factor products, and have caused other States to contemplate the 

same action. In addition, some States volunteered that they had asked drug providers for 

invoices to substantiate claims that the revised prices were below acquisition costs. These 

States reported that invoice data was either not provided, or provided only for a very 

small number of drug codes (less than 10). In these cases, the States made revisions to 

prices based on the invoice data. 

The majority of the 19 States that are not using the revised prices felt that the prices may 

be too low, especially when a percentage discount is subtracted. Four of these 19 States 

actually used the revised prices at one time, but later reversed their decisions. Some 

States noted they checked with area wholesalers and distributors, and subsequently 

determined that the revised prices were not readily available to providers in their State. 

States using the revised prices believe they will lead to 

short-term savings, but are unsure of the long-term impact 

Of the 30 States currently using the revised prices, 24 believed there will be short-term 

cost savings. These States reported that short-term savings were inevitable due to 

significant per-unit price reductions for these drugs. However, some States suggested the 

savings would be small because there was low utilization for the drugs with revised prices, 

or that utilization for these drugs would simply shift to other products. 

Seven States provided an estimate of annual cost savings that would result from their drug 

price revisions. Each of these estimates was based on the assumption that utilization 

would remain constant. The States estimated annual savings between $800,000 and $7 

million. 

Twenty of the 30 States using the revised prices either did not believe or were unsure that 

the revised prices would result in long-term cost savings. Many of these States felt that 

Medicaid’s Use of Revised Average Wholesale Prices 7 OEI-03-01-00010 
providers and manufacturers would find ways to circumvent the new prices. For instance, 

manufacturers could obtain new national drug codes for products with revised prices and 

report a higher average wholesale price for the new code. Because First DataBank only 

reported revised prices for the national drug codes that were supplied by the Justice 

Department and the NAMFCU, Medicaid would pay the higher prices reported for the 

newly-issued national drug codes. Furthermore, because the revised prices were issued on 

a product-specific and not a drug-class level, providers could substitute drugs with higherpriced national drug codes in place of codes with revised prices. 

Medicaid’s Use of Revised Average Wholesale Prices 8 OEI-03-01-00010 
CONCLUSION 

Over the last several years, the OIG has produced a significant body of work that clearly 

demonstrates the inflated nature of reported average wholesale prices. Because most 

States base their reimbursement for drugs on average wholesale prices, this inflation has 

caused Medicaid to pay too much for certain products. Therefore, we commend any 

efforts to obtain more accurate pricing for the Medicaid program. 

This report shows that some States are benefitting from the revised average wholesale 

prices prompted by the actions of the Justice Department and the NAMFCU. However, 

States’ concerns about the revised prices indicate that attempting to lower reimbursement 

simply by further reducing average wholesale prices may not be an effective long-term 

solution. Therefore, we continue to believe that the current system’s reliance on reported 

average wholesale prices as a basis for drug reimbursement is fundamentally flawed. 

Agency Comments 

The CMS agreed with our conclusion that the reliance on reported average wholesale 

prices as a basis for drug reimbursement is problematic, and stated that they will continue 

to look for administrative and legislative solutions to this problem. In addition, the CMS 

made two technical comments concerning items in the draft report. We have addressed 

the technical comments in this final version of the report. The full text of CMS’ comments 

is presented in Appendix B. 

Medicaid’s Use of Revised Average Wholesale Prices 9 OEI-03-01-00010 
APPENDIX A 

Use of Revised Average Wholesale Prices by State

State 

Uses Revised Prices for 

Pharmacy Drugs 

Uses Revised Prices for 

Physician Drugs 

Subtracts Discount from 

Revised Price 

Alabama 1 x x x 

Alaska x 

Arizona 

Arkansas 

California 

Colorado 

Connecticut x x 

Delaware x x 

District of Columbia 2 x x 

Florida x 

Georgia 

Hawaii 3 x x x 

Idaho 4 x x 

Illinois x 

Indiana 2 x x x 

Iowa 

Kansas 4 x x 

Kentucky 5 

Louisiana 

Maine 

Maryland x x 

Massachusetts 

Michigan 

Minnesota 5 

Mississippi 

Missouri 5 

Montana x 

Nebraska 

Nevada x x 

New Hampshire x x 

New Jersey x 

New Mexico x x 

New York x x 

North Carolina 

Medicaid’s Use of Revised Average Wholesale Prices 10 OEI-03-01-00010 
APPENDIX A 

State 

Uses Revised Prices for 

Pharmacy Drugs 

Uses Revised Prices for 

Physician Drugs 

Subtracts Discount from 

Revised Price 

North Dakota 5 

Ohio 1 x x 

Oklahoma x x 

Oregon 4 x x x 

Pennsylvania x x x 

Rhode Island 

South Dakota 

South Carolina x x x 

Tennessee 6 x x 

Texas 1, 4 x 

Utah x 

Vermont x x 

Virginia 

Washington x 

West Virginia x 

Wisconsin 7 x x x 

Wyoming 

Source: OIG Survey of Medicaid States, January - March 2001 

1 State does not use revised prices for many of the affected drugs because State relies on methods other than 

average wholesale price as its primary reimbursement methodology. 

2 State no longer uses revised prices for blood-factor products based on complaints from providers. 

3 Revised prices not available to all State contractors. 

4 For a small number of national drug codes, State no longer uses revised prices since invoices sent by providers 

indicated prices were too low. 

5 State used revised prices at one time, but no longer does so. 

6 Most drugs are paid through a managed care organization. Only drugs provided to dual-eligible 

Medicare/Medicaid recipients and behavioral-health drugs are reimbursed through the pharmacy program. 

7 State does not use revised prices for drugs with State maximum allowable costs. 

Medicaid’s Use of Revised Average Wholesale Prices 11 OEI-03-01-00010 
APPENDIX B 

Health Care Financing Administration Comments

Medicaid’s Use of Revised Average Wholesale Prices 12 OEI-03-01-00010 
APPENDIX B 

Medicaid’s Use of Revised Average Wholesale Prices 13 OEI-03-01-00010