October 1, 2026
Rx Pricing: Part B MFN Rule & Part D Implications
While CMS’s finalized GLOBE most favored nation (MFN) rule for Medicare Part B meaningfully narrows its reach / implications, we view its methodology for excluding manufacturers participating in the GENEROUS MFN Medicaid model as legally…
July 27, 2026
Rx Pricing: MFN Risks & Path Ahead
With the GUARD (Part D) & GLOBE (Part B) most favored nation (MFN) models under review at the White House, we give ~80% odds to the administration moving forward with final rules, where our estimates…
March 24, 2026
Rx Pricing: MFN “Deals” & Legal Landmines
Our review of comment submissions for CMS’s most favored nation (MFN) drug pricing model proposals in Medicare Part D (GUARD) and B (GLOBE) leave us with just ~30% odds of their being implemented. The risk…
December 21, 2025
Rx Model Risks: So Much For “Deals”
CMS’s mandatory Medicare Part D (here) / Part B (here) international drug pricing model proposals released Friday suggest that – besides an ostensible reprieve from as yet unrealized tariffs – recent drug manufacturer “deals” with…