GeneraL Objections to provider Burden and Economics: An analysis of stakeholder comments on the proposed GLOBE model
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We discuss the key learnings from 151 public comment letters on the proposed Global Benchmark for Efficient Drug Pricing (GLOBE) model.
Executive takeaway
The GLOBE public comments appear materially more mixed than the GUARD comments. The center of gravity is not simple opposition to lower prices in the abstract, but the concern that a Part B reference-pricing model could disrupt office-based drug delivery, continuity of care, and the economics of buy-and-bill administration.
Background
CMS describes GLOBE as a five-year proposed model for clinician-administered drugs, with a proposed launch date of October 1, 2026, a planned end date of September 30, 2031, and comment submissions due February 23, 2026. The public-facing CMS materials frame GLOBE as a global-benchmarking model for drugs administered in clinical settings, including oncology and autoimmune…
