Rules › CMS-2025-1889

Global Benchmark for Efficient Drug Pricing (GLOBE) Model

Proposed rule from the Health and Human Services Department, Centers for Medicare & Medicaid Services (docket CMS-2025-1889). 140 comment letters from companies and organizations are listed below.

Agency: Health and Human Services Department, Centers for Medicare & Medicaid Services
Docket: CMS-2025-1889
Published: 2025-12-23
Comments due: 2026-02-23
Status: Comment period closed February 23, 2026 · no final rule found yet
Total public comments: 20,168
Letters listed here: 140

Federal Register notice ↗ · Docket on Regulations.gov ↗

Who commented, by industry

Pharma & Medical Devices 57 Healthcare 53 Advocacy & Nonprofits 19 Insurance 3 Education 3 Business Groups & Chambers 3 Technology, Media & Telecom 1 Manufacturing & Chemicals 1

Who commented

Recordati Rare Diseases, Inc. Company Pharma & Medical Devices

filed 2026-02-25

Global Benchmark for Efficient Drug Pricing (GLOBE) Model

Who commented, by industry

Who commented

Recordati Rare Diseases, Inc. Company Pharma & Medical Devices

Astellas Pharma US, Inc. Company Pharma & Medical Devices

Merck Company Pharma & Medical Devices

National Association of Specialty Pharmacy Trade or professional group Pharma & Medical Devices

The US Oncology Network Nonprofit or advocacy group Healthcare

American Society of Gene and Cell Therapy Trade or professional group Healthcare

BioNJ Trade or professional group Pharma & Medical Devices

Pharmaceutical Research and Manufacturers of America (PhRMA) Trade or professional group Pharma & Medical Devices

Center for Innovation and Free Enterprise Nonprofit or advocacy group Advocacy & Nonprofits

Ferring Pharmaceuticals Company Pharma & Medical Devices

Institute for Gene Therapies (IGT) Trade or professional group Pharma & Medical Devices

Association of Cancer Care Centers (ACCC) Trade or professional group Healthcare

Personalized Medicine Coalition Trade or professional group Healthcare

Neurotech Pharmaceuticals, Inc. Company Pharma & Medical Devices

America First Policy Institute Nonprofit or advocacy group Advocacy & Nonprofits

National Minority Quality Forum Trade or professional group Healthcare

Boehringer Ingelheim Company Pharma & Medical Devices

ICAN, International Cancer Advocacy Network Nonprofit or advocacy group Healthcare

BlueRock Thereapeutics Company Pharma & Medical Devices

U.S. Pharmacopeia Nonprofit or advocacy group Pharma & Medical Devices

ISPOR Trade or professional group Healthcare

Point32Health Company Insurance

Alliance for Regenerative Medicine Trade or professional group Pharma & Medical Devices

National Home Infusion Association (NHIA) Trade or professional group Healthcare

Biocom Trade or professional group Pharma & Medical Devices

American Pharmacists Association Trade or professional group Healthcare

American Cancer Society Cancer Action Network (ACS CAN) Trade or professional group Healthcare

Biogen Company Pharma & Medical Devices

California Life Sciences (CLS) Trade or professional group Pharma & Medical Devices

GSK Company Pharma & Medical Devices

Rare Disease Company Coalition Trade or professional group Pharma & Medical Devices

Teva Pharmaceuticals Company Pharma & Medical Devices

Information Technology and Innovation Foundation (ITIF) Nonprofit or advocacy group Technology, Media & Telecom

Citizens Against Government Waste Nonprofit or advocacy group Advocacy & Nonprofits

AbbVie Company Pharma & Medical Devices

Academy of Managed Care Pharmacy (AMCP) Trade or professional group Pharma & Medical Devices

AstraZeneca Company Pharma & Medical Devices

Incyte Corporation Company Pharma & Medical Devices

The Yale Collaboration for Regulatory Rigor, Integrity, and Transparency (CRRIT) University or school Education

Eli Lilly and Company Company Pharma & Medical Devices

AHIP Trade or professional group Insurance

National Home Infusion Association (NHIA) Trade or professional group Healthcare

Catalyst Pharmaceuticals Company Pharma & Medical Devices

Genentech Company Pharma & Medical Devices

Grifols Company Pharma & Medical Devices

Immune Deficiency Foundation Nonprofit or advocacy group Healthcare

Massachusetts Biotechnology Council (MassBio) Trade or professional group Pharma & Medical Devices

University of Arkansas for Medical Sciences University or school Education

U.S. Chamber of Commerce Trade or professional group Business Groups & Chambers

Council for Affordable Health Coverage Trade or professional group Healthcare

Bristol Myers Squibb Company Pharma & Medical Devices

Community Access National Network Nonprofit or advocacy group Healthcare

Gilead Sciences, Inc. Company Pharma & Medical Devices

McKesson Corporation Company Pharma & Medical Devices

National Pharmaceutical Council Trade or professional group Pharma & Medical Devices

Competitive Enterprise Institute Nonprofit or advocacy group Advocacy & Nonprofits

ASHP Trade or professional group Healthcare

Alnylam Pharmacueticals Company Pharma & Medical Devices

CSL Behring Company Pharma & Medical Devices

National Taxpayers Union Nonprofit or advocacy group Advocacy & Nonprofits

Assertio Holdings, Inc. Company Pharma & Medical Devices

The Pharmaceutical Care Management Association (PCMA) Trade or professional group Pharma & Medical Devices

Lundbeck Pharmaceuticals LLC Company Pharma & Medical Devices

American Commitment Nonprofit or advocacy group Advocacy & Nonprofits

Alivia Health Hospital or health provider Healthcare

Medical Imaging and Technology Alliance Trade or professional group Pharma & Medical Devices

CG Oncology Company Pharma & Medical Devices

National Association of Manufacturers (NAM) Trade or professional group Manufacturing & Chemicals

RetireSafe Nonprofit or advocacy group Advocacy & Nonprofits

Neurocrine Biosciences, Inc. Company Pharma & Medical Devices

Association for Clinical Oncology (ASCO) Trade or professional group Healthcare

Small Business & Entrepreneurship Council Trade or professional group Business Groups & Chambers

Center for Individual Freedom (CFIF) Nonprofit or advocacy group Advocacy & Nonprofits

Coalition of State Rheumatology Organizations Trade or professional group Healthcare

Cancer Support Community Nonprofit or advocacy group Healthcare

Immatics US Inc Company Pharma & Medical Devices

Alliance for Transparent & Affordable Prescriptions (ATAP) Action Network Trade or professional group Healthcare