announcedmandatory

GUARD

Guarding U.S. Medicare Against Rising Drug Costs

The Guarding U.S. Medicare Against Rising Drug Costs (GUARD) Model is a proposed mandatory model that would assess rebates for certain drugs payable under Medicare Part D if the prices exceed those paid in economically comparable countries. CMS expects GUARD would reduce out-of-pocket drug costs for people with Medicare and result in savings to Medicare while preserving or enhancing beneficiaries’ quality of care.

Active Since2027-01-01

Innovation

Requires manufacturer rebates when the price of a Medicare Part D drug exceeds an international benchmark based on what other comparable countries pay.

The Problem

Prices for certain drugs in the U.S. are much higher than in other countries and this gap is increasing over time, driving up premiums in the Medicare Part D program and making it challenging for some older adults with Medicare Part D to afford their prescriptions.

The Solution

Under GUARD, CMS would require manufacturer rebates when the price of the drug exceeds that of an international benchmark based on what other comparable countries pay — making the net cost to Medicare for certain Part D drugs similar to what other comparable countries pay.

Expected Outcomes

The model would help make critical medications more affordable for Medicare Part D enrollees, while preserving or enhancing beneficiaries’ quality of care.

Strategy

By ensuring choice and price fairness for prescription drugs, GUARD advances the Innovation Center’s commitment to help people with Medicare live healthier lives, while also promoting the sustainability of the Medicare program.

Model Goals

  • Reduce out-of-pocket drug costs for people with Medicare
  • Result in savings to Medicare
  • Preserve or enhance beneficiaries’ quality of care

Patient Eligibility

Older adults and people enrolled in Medicare Part D.

  • Enrolled in Medicare Part D

Provider Eligibility

Manufacturers of certain drugs payable under Medicare Part D.

  • Manufacturer of certain Part D drugs whose prices exceed international benchmarks

CMS Benchmarks & Thresholds

operational

Rebate Reconciliation End Year2,033
Performance Period Duration5
Performance Period End Date2031-12-31
Public Comment Deadline2026-02-23
Performance Period Start Date2027-01-01

Is this model right for your organization?

Answer three quick questions about your facility and get matched to the VBC models that fit your profile with verified benchmark context.

Start Your Analysis