King & Spalding·HEALTHCARE

CMS Finalizes GLOBE Model Tying Part B Drug Payments to Foreign Prices

CMS-5545-F implements the mandatory GLOBE model under SSA section 1115A, benchmarking Medicare Part B drug payments against international reference prices.

What happened: On September 30, 2026, CMS issued final rule CMS-5545-F at 42 C.F.R. Part 513, implementing the Global Benchmark for Efficient Drug Pricing (GLOBE) Model — a mandatory Medicare payment model authorized under Social Security Act section 1115A. The framework ties Part B drug payment amounts to international reference benchmarks rather than domestic pricing alone.

Why sophisticated counsel and clients care: Part B covers physician-administered and certain infused biologics and oncology drugs, so a benchmarking mechanism anchored to foreign prices touches reimbursement planning, pricing and rebate compliance, government price reporting, and distribution arrangements for a broad set of manufacturer and provider clients. A mandatory model, rather than a voluntary demonstration, also raises operational questions — contract terms, chargeback and rebate mechanics, and internal controls across pricing, finance and compliance teams — and how the model interacts with existing Medicare negotiation authorities and ASP-based payment methodologies. The broader signal is a continued federal push to import international reference pricing into US public payer reimbursement.

Next steps to watch: effective and compliance dates, any transition provisions for manufacturers and pharmacies, CMS implementation guidance and claims-system changes, and industry comment or litigation challenging the model's statutory basis. The excerpt does not identify benchmark countries, drug scope or discount percentages; confirm those against the rule text before advising clients.

cms-final-rulemedicare-part-binternational-reference-pricingdrug-pricingsection-1115arebateshealthcare-reimbursement
Read the original firm alert → Wednesday, October 14, 2026

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