Goodwin Procter·HEALTHCARE

CMS Finalizes Scaled-Down GLOBE Drug Pricing Model for Medicare Part B

CMS released the final rule for the GLOBE Medicare Part B drug pricing model on September 30, 2026, narrowing the demonstration it proposed in December 2025 — a direct pricing and reimbursement change for manufacturers and Part B sponsors.

CMS published the final rule for the Global Benchmark for Efficient Drug Pricing (GLOBE) Model on September 30, 2026, following a proposed rule issued December 23, 2025 under its demonstration authority. According to the coverage summarized here, the agency scaled the model back from the proposal, making the final scope materially narrower than practitioners had modeled. For clients, the significance is direct and dollar-denominated: GLOBE governs how prices for Medicare Part B drugs are established and tested against a global benchmark, which affects manufacturer pricing strategy, Part B plan liability, and the commercial-coordination negotiations sitting behind Part B coverage.

Sophisticated counsel and clients should read the operative regulatory text rather than the alert. Three things drive the read: the final covered-drug list and any benchmarks or data sources adopted, the price-adjustment and reporting mechanics for participating manufacturers, and the participation requirements for Part B plans, including how the benchmark interacts with existing ASP-based payment. Pricing compliance, rebate and chargeback drafting, and government-pricing exposure are the likely downstream workstreams.

Next to watch: CMS implementing guidance, the model's effective and end dates, and initial plan or manufacturer participation decisions. Coverage here is a single law-firm alert with a partial excerpt, so scope, timing, and any figures should be confirmed against the Federal Register text before reliance.

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Read the original firm alert → Tuesday, October 20, 2026

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