The Center for American Principles submitted a formal public comment to the Centers for Medicare & Medicaid Services (CMS) opposing the proposed “Global Benchmark for Efficient Drug Pricing” (GLOBE) Model.
In the comment, CAP argues that the GLOBE proposal would unlawfully restructure Medicare Part B by importing foreign price-control mechanisms into physician-administered drug markets. The model would tie U.S. reimbursement rates for certain Part B therapies to benchmarks established by government authorities in 19 foreign countries, replacing market-based payment structures with centralized price administration.
CAP warns that the proposal exceeds the statutory authority granted to the Center for Medicare and Medicaid Innovation (CMMI). Rather than testing a limited, voluntary reform, the GLOBE model would impose a mandatory pricing scheme affecting approximately one-quarter of Medicare beneficiaries through geographic assignment. CAP contends that such a sweeping intervention cannot credibly be characterized as a lawful demonstration project.
The comment further explains that Part B supports complex, physician-administered therapies used to treat serious and life-threatening conditions including cancer, autoimmune disease, and rare disorders. Tethering U.S. reimbursement to foreign government price-setting systems risks undermining provider stability, restricting patient access, and overriding physician judgment in highly individualized treatment decisions.
CAP also notes that CMS acknowledges the proposal is unlikely to generate meaningful out-of-pocket savings for most beneficiaries, many of whom have supplemental coverage that already mitigates cost sharing. Meanwhile, the broader consequences of price-setting policies threaten to reduce research investment, slow the development of future therapies, and weaken America’s global leadership in biomedical innovation at a time of intensifying competition from China.
CAP concludes that the GLOBE model replaces market-based payment with foreign price controls, undermines patient-centered care, and fails to deliver meaningful savings to seniors. For these reasons, CAP urges CMS to withdraw the proposed rule in its entirety.