The Centers for Medicare & Medicaid Services (CMS) on Dec. 23 published two proposed rules for implementing alternative drug pricing models, both of which aim to expand the Trump Administration's Most Favored Nation (MFN) drug pricing policies.

The first proposed rule would establish the Global Benchmark for Efficient Drug Pricing (GLOBE) Model, which intends to test a new means of measuring drug price inflation. Under current policy, the Medicare Part B Inflation Rebate Program uses a benchmark derived from domestic drug pricing. The proposed rule would instead derive that benchmark from manufacturer-reported international pricing. CMS proposes to run the model for seven years total, from Oct. 1, 2026, to Sept. 30, 2033.

The second proposed rule would establish the Guarding U.S. Medicare Against Rising Drug Costs (GUARD) Model. The GUARD model would test how changes to the Part D inflation rebate impact costs for the Medicare program. The model is scheduled to run from Jan 1, 2027 to Dec. 31, 2035.

These proposed rules follow recent administrative action to impose MFN policies in Medicaid first announced in May.

Both proposed rules have public comment periods running until Feb. 23, 2026.

Contact Director of Policy Rob Nelb, MPH, at [email protected] or 202.585.0127 with questions.