AMCP Comment Letter on Global Benchmark for Efficient Drug Pricing (GLOBE) Model to HHS

AMCP appreciates CMS’s efforts to explore alternative payment approaches to address rising Medicare Part B drug spending and recognizes the importance of testing innovative models through CMMI. At the same time, effective model testing requires designs that are operationally feasible, analytically sound, and aligned with beneficiary protection objectives. As proposed, the GLOBE Model raises concerns regarding administrative complexity, benchmark reliability, beneficiary affordability, and cross-program impacts that warrant further refinement prior to finalization.

Full Letter