Lexology January 15, 2026
The Center for Medicare and Medicaid Innovation (CMMI)[1] recently released information about three new models aimed at testing alternative calculations for manufacturer rebates, to ensure net drug prices are closer to those in economically comparable countries.
In December 2025, CMMI released two separate notices of proposed rulemaking for the Global Benchmark for Efficient Drug Pricing (GLOBE) Model and the Guarding US Medicare Against Rising Drug Costs (GUARD) Model, and a Request for Applications for applicable manufacturers for its Generating Cost Reductions for US Medicaid (GENEROUS) Model. Both the GLOBE and GUARD Models are proposed rules and may therefore differ from what is ultimately finalized.
Public comments on the GLOBE and GUARD proposed rules are due on February 23, 2026. The...
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