Is International Pricing Coming Onshore for Testing? CMS Proposes Models Tying Medicare Part B and Part D Drug Rebates to International Pricing

Lexology December 30, 2025
Ropes & Gray LLP

On December 19, 2025, the Centers for Medicare & Medicaid Services (“CMS”) proposed two mandatory Center for Medicare and Medicaid Innovation (“CMMI”) drug payment models to test whether alternative methods for calculating Medicare rebates, based on international pricing metrics rather than inflation-based metrics, reduce costs for Medicare fee-for-service (“FFS”) beneficiaries and the Medicare program while preserving quality of care. The first model, the Global Benchmark for Efficient Drug Pricing (“GLOBE”) Model, would consider, for select Medicare Part B products, a rebate derived from international prices instead of the current inflation-based rebate.¹ The second model, the Guarding U.S. Medicare Against Rising Drug Costs (“GUARD”) Model, would similarly test an alternative approach to calculating rebates for certain Medicare Part D products using...

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