The EACH/PIC Coalition submitted comments to the Centers for Medicare and Medicaid Services (CMS) on the proposed GLOBE model, which would implement most-favored-nation (MFN) style pricing for Medicare Part B. The letter outlines that the demonstration would be unlikely to meaningfully lower what patients pay for their medications and urges for patient-centered reforms that would better address their needs.
The letter stated:
“The GLOBE model aims to reduce Medicare drug costs by requiring rebates for drugs based on international pricing; however, the model is unlikely to reduce out-of-pocket costs for beneficiaries. Patient costs are determined by insurance coverage policies, coinsurance structures, and supplemental coverage, not by Medicare’s underlying payment benchmark alone.”
“Independent analysis underscores this disconnect. A recent Avalere Health assessment of MFN-style pricing under the GLOBE model found that only approximately 0.3 percent of Medicare fee-for-service beneficiaries would be directly exposed to any change in cost-sharing liability under the model’s structure. The analysis further found that the vast majority of beneficiaries using Part B drugs have supplemental coverage that already offsets standard coinsurance, meaning that more than 99 percent of beneficiaries would experience no reduction in out-of-pocket costs at all, even if Medicare payment amounts decline.”
“These findings highlight a fundamental limitation of the GLOBE model: lower program spending does not inherently result in lower patient costs. As proposed, the GLOBE demonstration prioritizes lowering federal spending rather than ensuring patient affordability.”
“There are more direct and effective ways to improve affordability for Medicare beneficiaries that are grounded in patient experience rather than blunt pricing mechanisms. Reforms that address insurance design, reduce harmful utilization management practices, improve transparency, and ensure that negotiated savings reach patients would do far more to lower what patients actually pay.”
“Patients consistently identify these structural factors as the primary drivers of their affordability challenges. CMS should prioritize reforms that respond to these realities.”
“While we appreciate CMS’s efforts to explore new models, the GLOBE demonstration is unlikely to deliver meaningful benefits to patients. Evidence indicates that very few beneficiaries would experience any reduction in out-of-pocket costs, while risks to access and continuity of care remain real.”
“We respectfully urge CMS to withdraw the proposed GLOBE demonstration and instead pursue patient-centered reforms that directly lower out-of-pocket costs, protect access, and reflect how patients actually experience affordability in the Medicare program.”