CMS Publishes Proposed Medicare MFN Models

On December 23, 2025, CMS published notices of proposed rulemaking for the GLOBE (Medicare Part B) and GUARD (Medicare Part D) most-favored nation drug pricing models.

Federal Register announcements:

• Federal Register :: Global Benchmark for Efficient Drug Pricing (GLOBE) Model
• Federal Register :: Guarding U.S. Medicare Against Rising Drug Costs (GUARD) Model

CMS announcements:

• GLOBE (Global Benchmark for Efficient Drug Pricing) Model | CMS
• GUARD (Guarding U.S. Medicare Against Rising Drug Costs) Model | CMS

Comments are due by February 23, 2026.