AMCP Comment Letter on Guarding U.S. Medicare Against Rising Drug Costs (GUARD) Model to HHS

The Academy of Managed Care Pharmacy (AMCP) appreciates CMS’s efforts to address rising drug costs through the proposed GUARD Model. While the model reflects an important policy objective, several aspects raise concerns for managed care pharmacy related to operational feasibility, pricing dynamics, and the extent to which anticipated savings will translate into meaningful benefits for plans and beneficiaries. The following comments highlight key areas where additional clarity and refinement are needed.

Full Letter