Lexology December 23, 2025
On Friday, December 19, the Centers for Medicare & Medicaid Services (CMS) announced two new pilot programs aimed at reducing Medicare spending on prescription drugs and reducing beneficiaries’ out-of-pocket costs. The Guarding U.S. Medicare Against Rising Drug Costs (GUARD) model, which targets Medicare Part D drug spending, would run from January 1, 2027 through December 31, 2031, and the Global Benchmark for Efficient Drug Pricing (GLOBE) model, which targets Medicare Part B drug spending, would run from October 1, 2026 through September 30, 2031, with reconciliation continuing into 2033 for both programs.
These pilot programs are designed to further the Trump administration’s goal of aligning US drug prices with those of other developed nations, often referred to as “most favored...







