On September 30, CMS finalized the Global Benchmark for Efficient Drug Pricing (GLOBE) Model, a mandatory model that tests an alternative way to calculate Part B inflation rebates for certain drugs, using international prices as a benchmark (CMS). The final rule takes effect November 30. The test period begins January 1, 2027, and the first performance year starts April 1, 2027.
What it is
CMS’s FAQ describes GLOBE as an alternative to the existing Part B inflation rebate calculation for selected drugs. It does not eliminate or replace that program. The participants are manufacturers. Providers are not participants and bill as usual, because CMS designed the model to operate within existing Medicare claims processing.
What it covers
GLOBE applies to single-source drugs and biologics with more than $100 million in annual Original Medicare Part B spending, in certain drug classes that include cancer drugs, immunological agents, and eye drugs (Managed Healthcare Executive). The beneficiary cohort is about 25% of people with Original Medicare as their primary payer, selected by ZIP code. Beneficiaries who have elected Medicare Advantage are not included (CMS FAQ). Manufacturers rebate any excess to CMS.
The final scope is much narrower than the proposal. CMS now estimates about $80 million in annual Part B savings, down from about $2.3 billion. PhRMA has said it considers the model unlawful. A companion Part D model, GUARD, has not yet been finalized.
What happens next
CMS will publish the list of included drug codes before each quarter and the model’s ZIP code list by January 16, 2027. It says it will monitor for shifts in drug utilization, including shifts from Part B to Part D, and for unintended access issues (CMS FAQ).
Why “rebate” needs a qualifier
Under GLOBE, a “Part B rebate” is an obligation a manufacturer owes CMS, calculated against an international benchmark and applied to Original Medicare. CMS’s FAQ describes a Medicare model and no commercial-market component.
The rebates plan sponsors track are different. They are the manufacturer rebates a health plan or employer receives on specialty drugs. PSG’s 2026 Trends in Specialty Drug Benefits Report found that 51% of respondents receive specialty drug rebates under the medical benefit, compared with 93% under the pharmacy benefit.
GLOBE is worth tracking as a Medicare development. It is separate from whether a commercial plan is receiving rebates on its own medical benefit drugs. PSG’s data shows that is not yet a given.
When “Part B rebates” comes up in your next planning conversation, is everyone in the room referring to the same rebate? Comment below.
Disclaimer: This newsletter references publicly available information from the Centers for Medicare & Medicaid Services, third-party legal and trade press coverage, and Pharmaceutical Strategies Group’s 2026 Trends in Specialty Drug Benefits Report. Federal policy details are subject to change, and this newsletter reflects sources available as of October 23, 2026. VativoRx is not affiliated with, endorsed by, or partnered with any organization referenced. This newsletter is provided for informational and educational purposes only and does not constitute legal, regulatory, or financial advice. Readers should consult appropriate advisors regarding specific circumstances.