Background

In 2025, the Trump administration advanced a series of regulatory and policy actions aimed at aligning US drug prices with those paid in economically comparable countries through Most-Favored Nation (MFN) pricing. In May, President Trump signed an Executive Order directing federal agencies to pursue policies advancing MFN pricing and to explore both mandatory and voluntary implementation pathways across federal healthcare programs.

On December 19, 2025, the CMS Innovation Center introduced the proposed Global Benchmark for Efficient Drug Pricing (GLOBE) Model, which would incorporate MFN pricing into Medicare Part B. Under this model, the Part B inflation rebate would be “modified” by comparing eligible drugs’ Average Sales Prices (ASPs) to an international benchmark price. For each applicable quarter, CMS would calculate the Part B inflation rebate (as implemented under the Inflation Reduction Act) and a GLOBE benchmark-based rebate, with manufacturers owing the greater of the two amounts for eligible drug units. Beneficiary cost sharing would be calculated based on the lower of the inflation-adjusted ASP or the MFN benchmark price. The model would apply to a randomly selected 25% sample of Medicare Part B fee-for-service (FFS) beneficiaries based on geographic location.

Against this policy backdrop, Avalere Health analyzed how MFN pricing could affect out-of-pocket (OOP) costs for FFS beneficiaries. The analysis focused on the share of FFS beneficiaries who use these eligible drugs and the extent to which they would have direct exposure to changes in cost-sharing liability, based on whether they had supplemental coverage that could reduce or eliminate their OOP costs. Avalere Health estimated utilization and supplemental coverage among a representative sample that included25% of beneficiaries.

Findings

Avalere Health found that only 0.3% of sampled FFS beneficiaries would be directly exposed to changes in OOP cost liability under the proposed GLOBE Model methodology, assuming the model applied to the 62 Part B drugs identified in the proposed rule. In 2022, fewer than 7% of FFS beneficiaries used any of these eligible drugs. Among beneficiaries who used eligible drugs, most had supplemental coverage (e.g., Medicaid, employer-sponsored insurance, or Medigap) that offsets the standard 20% Part B coinsurance. Only about 5% of sampled FFS beneficiaries lacked any form of supplemental insurance.

Drug utilization patterns and supplemental coverage rates in the full Medicare FFS population mirror those observed in the sample; roughly 1.7 million FFS beneficiaries used any eligible drug, and fewer than 22,000 would be exposed to cost-sharing liability changes under the model design.

Conclusion

Avalere Health’s analysis indicates that implementing the GLOBE Model would result in limited OOP savings for FFS beneficiaries. This reflects both the relatively small share of beneficiaries using drugs likely to be eligible under the GLOBE Model and the widespread availability of supplemental coverage that limits Part B cost-sharing exposure.

Methodology

Avalere Health analyzed the potential impact of MFN pricing policies on a subset of Medicare Part B drugs. The analysis focused on the 62 Part B drugs identified in the GLOBE Model proposed rule that meet the proposed drug eligibility criteria. We used 2022 Medicare Current Beneficiary Survey cost and utilization files to identify Medicare FFS beneficiaries with supplemental coverage and to link beneficiaries to utilization of any eligible Part B drugs.

The analytic sample was limited to beneficiaries with 12 months of continuous enrollment in Medicare Parts A and B and no enrollment in a Medicare Advantage plan at any point during the survey year. Beneficiaries were attributed to a source of supplemental coverage if they had more than six months of enrollment in a given coverage type during the survey year. When beneficiaries had more than one source of supplemental coverage, a single source was assigned using the following hierarchy: (1) Medicaid, (2) employer-sponsored insurance, (3) Medigap, and (4) other coverage.

Survey weights were applied to extrapolate beneficiary counts to the national Medicare FFS population. A sufficient sample of beneficiaries attributed to each source of supplemental coverage was required to be included in the results; sample sizes of <11 were excluded. Finally, a 25% sample was applied to the extrapolated national FFS population to mirror the population selection methodology used in the GLOBE Model.

Learn More

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Funding for this research was provided by PhRMA; Avalere Health retained full editorial control.