Center for American Principles

Participation in the 340B program does not appear to have increased care or improved outcomes for patients in underserved areas. According to an Agency for Healthcare Research and Quality (AHRQ)-funded study, “financial gains for [340B] hospitals have not been associated with clear evidence of expanded care or lower mortality among low-income patients.” 340B is only making hospitals richer, not serving low income patients. @HouseCommerce

@CMSInnovates has expanded its reach despite years of missed cost and quality goals. CAP urges Congress to get rid of the program and restore transparency in healthcare policy.@HouseGOP @SenateGOP @GovWaste ccagw.org/letters_to_off…

@CMSInnovates has expanded its reach despite years of missed cost and quality goals. CAP urges Congress to get rid of the program and restore transparency in healthcare policy. @HouseGOP @SenateGOP @GovWaste ccagw.org/letters_to_off…

Vote No on Bernie Sanders Amendments @SenateHELP atr.org/atr-urges-help…

@POTUS is right to focus on affordability in tonight's SOTU. But MFN is government price controls by another name. Price controls hurt patient access, weaken innovation, and run counter to conservative, free-market principles.

CAP submits public comment on GUARD Model. @POTUS @HouseCommerce @WaysandMeansGOP @SenateGOP CENTERFORAMERICANPRINCIPLES.ORG February 23, 2026 Dr. Mehmet Oz Administrator Centers for Medicare & Medicaid Services 7500 Security Boulevard Baltimore, MD 21244 RE: Guarding U.S. Medicare Against Rising Drug Costs (GUARD) Model, CMS-5546-P Dear Administrator Oz: The Center for American Principles (CAP) submits this comment in response to the proposed "Guarding U.S. Medicare Against Rising Drug Costs" (GUARD) model. By applying a foreign price-control scheme to Medicare's prescription drug benefit, Part D, CMS would impose a sweeping, unlawful policy that will fail patients on both cost and access and weaken America's global leadership in innovation. These concerns are central to the work of the Center for American Principles. CAP is a 501(c)(4) nonprofit issue-advocacy organization that advances sound policy solutions based on American core principles and brings attention to the increasing threats facing Americans from government intervention in markets and bureaucratic overreach. Our mission is to protect and promote individual freedoms, free enterprise, limited government, the rule of law, and a strong national defense. The GUARD model directly conflicts with these principles and should be withdrawn. Congress created the Center for Medicare and Medicaid Innovation (CMMI) to test limited, voluntary, and narrowly tailored payment and delivery reforms. It did not authorize CMMI to restructure Medicare Part D for a significant share of beneficiaries nationwide through a mandatory, multi-year price control model. The proposed GUARD rule relies on an arbitrary geographic design that randomly selects ZIP-code areas to capture 25% of Part D enrollees. This is a dangerous government overreach in an attempt to induce nationwide market behavior changes not supported by law under the guise of satisfying statutory "test" requirements. 1 of 3Since its inception, Medicare Part D has relied on private sector competition to deliver broad access and choice for seniors' outpatient prescription drugs. The GUARD model abandons that structure. Under the proposed model, U.S. prices for certain Part D drugs would be tethered to benchmarks set by government authorities in 19 foreign countries, including the United Kingdom, Germany, France, Japan, and Canada -- systems that rely on centralized price-setting. By tying U.S. prices to foreign government decisions, CMS replaces the competitive dynamics that made Part D successful with centralized price administration, contradicting the program's statutory design. CMS would compel compliance with the model notwithstanding unresolved questions regarding its authority. The model establishes a pricing benchmark based on the lowest prices observed among the reference countries and enforces that benchmark through government-imposed rebates when U.S. prices exceed foreign levels. Manufacturers may avoid this outcome only by "voluntarily" submitting proprietary international pricing data, in which case CMS would instead rely on a foreign-weighted average. This framework is reinforced by civil monetary penalties equal to 125% of unpaid rebate amounts, amounting to significant coercion on manufacturers, notwithstanding that federal agencies lack the authority to unilaterally create and enforce punitive financial penalties. The premise underlying the GUARD proposal and other federal price-setting proposals -- that foreign drug prices reflect fair value -- is itself deeply flawed. Most of the countries that CMS proposes to reference rely on rigid value-assessment frameworks that prioritize budget constraints over patient outcomes, routinely restricting access to new therapies or delaying availability. Importing these benchmarks risks embedding those same access limitations into Part D and adopting discriminatory valuation tools that override physician judgment. The risk is especially acute because the GUARD model targets drugs that lack generic or biosimilar competition, leaving many patients without clinically appropriate alternatives for serious and chronic conditions. The model even affects Medicare's six protected therapeutic classes, which are safeguards Congress established to ensure access to treatments for serious conditions like cancer, HIV, and epilepsy. Although formal coverage requirements may remain unchanged, the financial incentives created by proposals like GUARD encourage plans to redesign benefits in ways that effectively restrict access. Plans will be driven to steer patients toward internationally benchmarked drugs and away from other appropriate options, disrupting stable treatment 2 of 3regimens and undermining physician decision-making for seniors with complex or life- threatening conditions. Notably, CMS itself concedes that GUARD rebates will do little to lower out-of-pocket costs. In fact, the GUARD model is estimated to increase Part D premiums and beneficiary cost sharing by approximately $3.6 billion. Meanwhile, the true drivers of patient affordability challenges are left unaddressed -- particularly supply chain intermediaries whose fees and rebate structures inflate and obscure costs without improving care. Beyond failing to deliver patient savings, the GUARD model -- like all federal price-setting schemes -- would carry serious consequences for America's innovation ecosystem. Policies that artificially devalue innovation predictably reduce research investment and delay future breakthroughs. Independent economic research indicates that importing foreign price-control models could result in the loss of hundreds of future drug treatments over the next decade -- potentially as many as 500 therapies and indications -- as companies are forced to scale back or abandon high-risk research programs. Federal price-setting proposals like GUARD risk accelerating the migration of early-stage development and production capacity to foreign competitors. At a moment when China is aggressively pursuing global leadership in biotechnology, dissociating Medicare Part D services from the market disciplines that enable advanced research, clinical trials, and manufacturing in the United States is a strategic mistake that will bring lasting harm to American patients, jobs, and national security. The GUARD model is an unlawful restructuring of Medicare Part D. The model replaces market disciplines with foreign price controls, undermines patient-centered care, and fails to deliver cost relief to seniors. For these reasons. CAP strongly urges CMS to withdraw the proposed model. Sincerely, Tony Zagotta Center for American Principles

CAP submits public comment on GLOBE Model. @POTUS @WaysandMeansGOP @HouseCommerce @SenateGOP CENTERFORAMERICANPRINCIPLES.ORG February 23, 2026 Dr. Mehmet Oz Administrator Centers for Medicare & Medicaid Services 7500 Security Boulevard Baltimore, MD 21244 RE: Global Benchmark for Efficient Drug Pricing (GLOBE) Model, CMS-5545-P Dear Administrator Oz: The Center for American Principles (CAP) submits this comment in response to the proposed "Global Benchmark for Efficient Drug Pricing" (GLOBE) model. By importing sweeping foreign price controls into Medicare Part B, CMS seeks to impose a policy that exceeds its statutory authority and would distort physician-administered drug markets, threaten patient access, and override the market disciplines that sustain American innovation. These concerns are central to the work of the Center for American Principles. CAP is a 501(c)(4) nonprofit issue-advocacy organization that advances sound policy solutions based on American core principles and brings attention to the increasing threats facing Americans from government intervention and bureaucratic overreach. Our mission is to protect and promote individual freedoms, free enterprise, limited government, the rule of law, and a strong national defense. The GLOBE model directly conflicts with these principles and should be withdrawn. Congress created the Center for Medicare and Medicaid Innovation (CMMI) to test limited, voluntary, and narrowly tailored payment reforms, not to impose mandatory price controls on a significant share of the Medicare population. Yet under the GLOBE model, CMS would subject approximately one-quarter of beneficiaries to a new pricing scheme based on geography, selected through random ZIP-code assignment. The scope and mandatory nature of this approach disqualify it as a lawful test under CMMI's statutory authority, given its scale and its obvious intent to influence market behavior nationwide. 1 of 3Part B is a critical aspect of Medicare that supports physician-administered therapies used to treat serious and often life-threatening conditions, including cancer, autoimmune disease, and rare disorders. These are frequently highly complex and environmentally sensitive biopharmaceutical products that are delivered in clinical settings where supporting infrastructure, continuity of care, provider judgment, and stable reimbursement are essential to their safe and effective utilization. The GLOBE model would replace market-based payments for these cutting-edge therapies with centralized price administration, ignoring clinical and economic realities. Under the proposed model, U.S. prices for certain Part B drugs would be tethered to benchmarks set by authorities in 19 foreign countries, including the United Kingdom, Germany, France, Japan, and Canada — systems that rely on government price-setting. By tying U.S. reimbursement to foreign government decisions, CMS departs from the statutory design of Medicare Part B and introduces uncertainty into provider-administered care. CMS compels compliance with the model notwithstanding unresolved questions regarding its authority. The model establishes a pricing benchmark based on the lowest prices observed among the reference countries and enforces that benchmark through government-imposed rebates when U.S. prices exceed foreign levels. Manufacturers may avoid this outcome only by "voluntarily" submitting proprietary international pricing data, in which case CMS would instead rely on a foreign-weighted average. This framework is reinforced by civil monetary penalties equal to 125% of unpaid rebate amounts, which represents significant coercion of manufacturers, notwithstanding that federal agencies lack the authority to unilaterally create and enforce punitive financial penalties. The premise underlying the GLOBE proposal and other federal price-setting proposals — that foreign drug prices reflect fair value — is itself deeply flawed. Most of the countries CMS proposes to reference rely on rigid value-assessment frameworks that prioritize budget constraints over patient outcomes, routinely restricting access to new therapies or delaying availability. Importing these benchmarks risks embedding those same access limitations into Part B and adopting discriminatory valuation tools that override physician judgment. This risk is especially acute because the GLOBE model focuses on physician-administered therapies in immunology, oncology, rheumatology, ophthalmology, and endocrinology, and because it targets drugs that lack generic or biosimilar competition — conditions under which treatment decisions are highly individualized and therapeutic substitution is often constrained. 2 of 3Moreover, CMS's assertion that lower Part B benchmark prices will meaningfully reduce beneficiary costs does not take into account the structure of Medicare coverage. Most Part B beneficiaries have supplemental insurance — including Medigap policies, employer-sponsored retiree coverage, or Medicaid — that already covers some or all of their coinsurance obligations. As a result, the GLOBE model is unlikely to produce meaningful out-of-pocket savings for most patients. More broadly, the GLOBE model — like all federal price-setting schemes — threatens the innovation ecosystem that has made our country a leader in biomedical research. Policies that artificially devalue innovation predictably reduce research investment and endanger future breakthroughs critical to addressing as-yet-unmet medical needs. Independent economic research indicates that importing foreign price-control models could result in the loss of hundreds of future drug treatments over the next decade — potentially as many as 500 therapies and indications — as companies are forced to scale back or abandon research programs. Federal price-setting proposals like GLOBE risk accelerating the migration of early-stage development and production capacity to foreign competitors. At a moment when China is aggressively pursuing global leadership in biotechnology, eroding the market disciplines that enable advanced research, clinical trials, and manufacturing in the United States is a strategic mistake that will bring lasting harm to American patients, jobs, and national security. The GLOBE model is an unlawful restructuring of Medicare Part B that replaces market-based payment with foreign price controls, undermines patient-centered care, and fails to deliver cost relief to seniors. For these reasons, CAP urges CMS to withdraw the GLOBE model proposal in its entirety. Sincerely, Tony Zagotta Center for American Principles

CAP joins 50 groups opposing Codification of MFN drug pricing. No to socialist price controls. @GroverNorquist @HouseCommerce @POTUS youtube.com/watch?v=W9kmcy…

CAP joins coalition opposing Most Favored Nation drug pricing @GroverNorquist @emilybrooksnews @POTUS atr.org/50-free-market…

CAP joins coalition letter calling for Congress to provide regulatory clarity and consistency for a national approach to AI governance. @AFPhq @HouseCommerce @SenateCommerce americansforprosperity.org/wp-content/upl…

Real health care reform doesn't mean more subsidies -- it means taking on insurers. In @TheWellNews, CAP President Anthony Zagotta explains how "enhanced" Obamacare subsidies reward fraud, enrich insurers, and leave patients worse off -- and what real, market-based reform should look like. thewellnews.com/opinions/real-… @POTUS @WaysandMeansGOP @HouseCommerce @SenateGOP

Health insurance CEOs testify on affordability in the House today. Voters already delivered the verdict. According to @IWCoalition, majorities across every age group say health insurance companies are the players policymakers must address. This's bipartisan consensus -- and a clear mandate. insurancewatchdogcoalition.com/americans-want… @POTUS @WaysandMeansGOP @HouseCommerce

Tomorrow, insurance CEO hearings in the House are a chance to get serious about reform. Instead of caving to extending wasteful subsidies, lawmakers should press insurers on fraud, upcoding, and middleman abuse that keep healthcare unaffordable. @HouseCommerce @WaysandMeansGOP @POTUS

As Congress prepares to question insurers on affordability, this investigation from @hntrbrkmedia should be required reading. GPOs and PBM practices are a major driver of hidden costs and abuse: hntrbrk.com/pbmgpo/ @POTUS @WaysandMeansGOP @HouseCommerce

If lawmakers are serious about fixing healthcare -- not just extending insurer handouts -- Health Savings Accounts are a place to start. HSAs put patients in control, encourage price transparency, and reduce the waste that thrives in today's opaque system. @POTUS @WaysandMeansGOP @HouseCommerce

x.com/RepJasonSmith/… Leadership means confronting what's broken, not papering over it. Chairman Smith has been clear: expanding subsidies won't fix a system plagued by fraud and abuse. @POTUS @WaysandMeansGOP @HouseCommerce

x.com/amresolve/stat… As long as insurers and PBMs dominate the system behind closed doors, costs will rise, and accountability will be nonexistent. Taking on the middlemen is essential to real savings for families and taxpayers. @POTUS @WaysandMeansGOP @HouseCommerce

President Trump is right: Obamacare empowered insurers, not patients. Years of subsidies and mandates have driven higher premiums, fewer choices, and massive insurer profits. It's time to fix the system. breitbart.com/politics/2026/… @POTUS @WaysandMeansGOP @HouseCommerce