Premier Weighs in on CMS Drug Pricing Models

Premier submitted comment letters in response to the Centers for Medicare & Medicaid Services (CMS)’ proposed Global Benchmark for Efficient Drug Pricing (GLOBE) and Guarding U.S. Medicare Against Rising Drug Costs (GUARD) models.

GLOBE Model Comments

The GLOBE Model is a proposed mandatory model designed to reduce Medicare Part B drug costs by benchmarking US drug prices against those paid in economically comparable countries. Under the model, if a drug’s price exceeds the international benchmark, manufacturers must pay additional rebates to Medicare. The model would operate in selected areas representing 25 percent of Medicare Part B beneficiaries enrolled in Traditional Medicare. CMS proposes a five-year model to begin Oct. 1, 2026, that would run through 2031, with rebate invoicing and reconciliation continuing into 2033.

In its comments, Premier recommends that CMS consider GLOBE’s impact on the following areas:

• Geographic area selection and beneficiary cost sharing
• Mandatory nature of the model
• Calculation of the average sales Price
• 340B program
• Manufacturer impact and innovation
• Complex pricing management for hospitals
• Downstream impact
• Implementation timeline and supply chain disruption

GUARD Model Comments

The GUARD Model is a proposed mandatory model designed to reduce Medicare Part D drug costs by benchmarking US drug prices against those paid in economically comparable countries. Under the model, if a drug’s price exceeds the international benchmark, manufacturers must pay additional rebates to Medicare. The model would operate in randomly selected geographic areas representing 25 percent of the people enrolled in a Medicare Part D plan. CMS proposes a five-year model to begin Jan. 1, 2027, that would run through 2031, with rebate invoicing and reconciliation continuing into 2033.

In its comments, Premier urges CMS to address these areas of concern prior to implementation to ensure the model does not inadvertently negatively impact patient care or impede access to care. Specifically, Premier recommends that CMS address GUARD’s potential impact with respect to the following areas:

• Manufacturer impact and innovation
• Impact on other drug pricing benchmarks
• Implementation timeline and supply chain disruption