Federal Policy
CMS Finalizes Mandatory MFN Drug Pricing Model for Part B
In a client alert, Hogan Lovells reports that CMS finalized a rule on September 30, 2026 establishing the mandatory GLOBE Model, a Most Favored Nation-based drug pricing approach in Medicare Part B. The model ties manufacturer rebate calculations under the Part B inflation rebate program to international pricing benchmarks for selected model drugs. It takes effect January 1, 2027, and will apply to manufacturers and providers administering affected Part B drugs. While the rule targets Medicare, its rebate and benchmark methodology could inform future Medicaid drug pricing policy discussions given overlapping manufacturer pricing obligations across federal programs.
Why it mattersManufacturers and providers must prepare for new rebate calculation methods tied to international benchmarks, and the precedent could shape future Medicaid drug pricing and rebate policy.