The Big Picture |
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The administration published two major health-related proposals on December 23, 2025: one that tightens “Transparency in Coverage” rules for employer and individual health plans, and another called the GLOBE Model that would benchmark some Medicare Part B drug prices to prices in a group of similar countries. The plan-transparency proposal would make price files smaller and easier to use (for example, showing in‑network rates by network rather than by plan, adding network names and enrollment counts, lowering the privacy threshold from 20 to 11 claims, and requiring a simple root .txt link and quarterly helper files), require the same cost‑estimate help by phone using the ID‑card number, and add a balance‑billing disclaimer; the phone and disclaimer rules would apply to plan years starting January 1, 2027 and most public‑file changes would take effect 12 months after the final rule is published. The GLOBE proposal would force manufacturers of covered single‑source Part B drugs to participate in an international price comparison, submit international net‑price data within 30 days after each quarter, and pay rebates where U.S. prices exceed the benchmark; if finalized it would begin October 1, 2026 for performance years running Oct. 1, 2026–Sept. 30, 2031 (payments through Sept. 30, 2033). Both proposals are open for public comment through February 23, 2026.
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Why this matters: together these rules try to make medical prices easier for patients and to lower what Medicare and beneficiaries pay for expensive outpatient medicines—CMS projects “billions” in savings over seven years for the GLOBE approach and expects lower coinsurance for affected patients. They also mark a clear policy direction: when Congress is largely inactive, the executive branch is using detailed regulation to reshape health‑care pricing and disclosure rather than waiting for new laws. That matters for insurers, hospitals, drug makers, patient advocates, and researchers because the rules change how data must be published, how often it must be updated (plans move to quarterly public files while drug files remain monthly), what information manufacturers must share, and when those changes must be implemented. Keep in mind these are proposals: final texts, effective dates, and legal challenges could alter timing or substance.
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Pattern to Watch |
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A noticeable pattern is the administration’s use of rulemaking to tackle health‑care costs through greater transparency and international price benchmarks. The indicators are two substantive Federal Register proposals filed on the same day (Dec. 23, 2025) with the same comment deadline (Feb. 23, 2026), concrete operational requirements (e.g., 30‑day quarterly data submissions from drug manufacturers, lowering the privacy threshold to 11 claims, phone cost estimates tied to the ID card), and explicit implementation dates (Jan. 1, 2027 for some plan provisions; Oct. 1, 2026 for GLOBE’s start). If continued, this approach could lower Medicare spending and patient out‑of‑pocket costs for certain drugs, change revenue dynamics for manufacturers, and improve usable price data for purchasers and researchers. Signals that the pattern is continuing or escalating would include final rules being published on similar timelines, CMS beginning to enforce data‑submission and rebate mechanics, public release of benchmarking calculations, an uptick in related rule proposals, industry compliance agreements, or major industry or legal challenges aimed at slowing implementation.
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