GLOBE Will Not Reduce Costs

CAHC provided comments on the proposed Global Benchmark for Efficient Drug Pricing (GLOBE) Model. We stated our concern that by taxing innovators through a mandatory rebate model, the GLOBE model will not achieve significant cost savings because it encourages higher prices to offset increased rebate liability. We highlighted that the model raises significant legal and evidentiary concerns under the statutory framework governing the Center for Medicare and Medicaid Innovation (CMMI). We encourage HHS to rescind the CMMI model and work with concerned citizens to address these problems before moving forward with any mandatory rebate model.