If you’re enrolled in Medicare Part D, you’ve likely felt the sting of rising prescription drug costs. The Centers for Medicare and Medicaid Services recently proposed a new mandatory payment model that could significantly change how you pay for your medications. The Guarding U.S. Medicare Against Rising Drug Costs Model, known as GUARD, aims to lower what you spend on prescriptions while protecting the quality of care you receive. Keep reading to learn more.

GUARD Model Overview
The GUARD Model represents one of the most significant changes to Medicare Part D drug pricing in recent years. At its core, this proposed model tests a new rebate formula for outpatient prescription drugs. These are the medications you typically pick up at your local retail pharmacy, receive through mail order services, or get through home infusion and long-term care pharmacies. The model’s primary goal is reducing what you pay out of pocket while ensuring you still have access to the treatments you need.
What makes this model particularly noteworthy is its approach to calculating drug prices. Rather than relying solely on domestic market factors, the GUARD Model incorporates international drug pricing information. CMS plans to use this data to establish benchmarks that reflect what economically comparable countries pay for the same medications. This international comparison approach could fundamentally shift how pharmaceutical manufacturers price their products for American consumers.
The model also builds upon existing Medicare Part D manufacturer rebates and discounts. Instead of creating an entirely new system, it modifies the current inflation rebate calculation. This means you won’t see a complete overhaul of how Part D works. Instead, the changes will happen within the existing framework, potentially making the transition smoother for both beneficiaries and healthcare providers.
Importance of Drug Pricing Reform
You might wonder why such dramatic changes to drug pricing are necessary. The numbers tell a compelling story about the current state of prescription costs in America. On average, Americans pay three times more than what people in other developed countries pay for identical medications. This disparity has real consequences for millions of seniors and individuals with disabilities who depend on Medicare for their healthcare coverage.
The financial burden of high drug prices forces many Medicare beneficiaries into impossible situations. Some older Americans must choose between filling their prescriptions and covering basic necessities like groceries or utility bills. Others stretch their medications by skipping doses, a dangerous practice that can lead to serious health complications. When you’re living on a fixed income, every dollar counts, and prescription costs can quickly consume a significant portion of your monthly budget.
Medicare Part D drug spending has grown to represent approximately 30 percent of all drug spending in the United States as of 2024. This substantial figure highlights why addressing Part D costs specifically could have such a meaningful impact on overall healthcare affordability. The GUARD Model targets this specific area because improvements here could benefit a large portion of the population while also helping to stabilize the Medicare Trust Fund for future generations.
How International Benchmarking Works
The international benchmarking component of the GUARD Model deserves closer examination because it’s central to how the program would achieve lower prices. Under this approach, CMS would look at what economically similar countries pay for certain drugs and use that information to set appropriate rebate levels. This doesn’t mean you’d be paying exactly what someone in Germany or Canada pays, but those prices would influence the calculations that determine manufacturer rebates.
This strategy responds directly to longstanding concerns about why Americans pay so much more for medications than people in other wealthy nations. Pharmaceutical companies have historically charged higher prices in the United States because the market has allowed it. By tying rebate calculations to international benchmarks, the GUARD Model creates pressure for more competitive pricing without implementing direct price controls.
The approach also maintains flexibility within the system. Rather than setting rigid price caps that could potentially limit access to newer medications, the model works through the rebate structure. Manufacturers would still have incentives to bring innovative treatments to market, but they’d face greater accountability for pricing decisions that significantly exceed what other developed nations consider reasonable.
Timeline and Geographic Implementation
If you’re wondering when these changes might affect your prescription costs, here’s what you need to know about the proposed timeline. The GUARD Model would begin on January 1, 2027, giving CMS, pharmacies, and pharmaceutical manufacturers time to prepare for implementation. The model itself would run for five years, with rebate invoicing and payment activities continuing through 2033.
One important detail about this model is that it won’t immediately apply to all Part D beneficiaries. The program would initially encompass 25 percent of Part D enrollees living in randomly selected geographic areas across the country. This phased approach allows CMS to test the model’s effectiveness and make adjustments before potentially expanding it nationwide. If you’re in one of the selected regions, you could see changes to your drug costs starting in 2027.
The geographic selection process means your location will determine whether you’re part of the initial rollout. CMS hasn’t yet announced which areas will be included, so you’ll want to stay updated on announcements as the implementation date approaches. Even if you’re not in an initial test area, the results from this model could shape future drug pricing policies that eventually affect all Medicare beneficiaries.
Potential Benefits and Considerations
The GUARD Model’s proponents argue it could deliver substantial savings for Medicare beneficiaries like you. By leveraging international pricing data, the model aims to close the gap between what Americans pay and what other developed nations pay for the same treatments. Lower rebate thresholds could translate into reduced premiums, lower copayments, and decreased out-of-pocket spending at the pharmacy counter.
Beyond individual savings, the model seeks to improve the overall sustainability of the Medicare program. As drug costs continue rising, they place increasing pressure on the Medicare Trust Fund. Finding ways to control these costs helps ensure that Medicare remains viable for current beneficiaries and future generations. You benefit not only from potential immediate savings but also from the long-term stability of a program you’ll likely rely on for years to come.
However, any significant change to drug pricing raises questions worth considering. Critics of international reference pricing models sometimes argue they could affect pharmaceutical innovation or drug availability. CMS has stated that the GUARD Model is designed to protect innovation while still achieving cost savings. As the proposal moves through the regulatory process, you’ll likely see ongoing debate about finding the right balance between affordability and maintaining a robust pharmaceutical marketplace.
The model also represents part of a broader effort to address drug costs across Medicare. CMS simultaneously proposed the GLOBE Model, which targets Medicare Part B drugs typically administered in clinical settings. Together, these initiatives signal a comprehensive approach to tackling prescription costs throughout the Medicare system. If you receive medications through both Part B and Part D, you could eventually see changes affecting multiple aspects of your coverage.
Conclusion
The proposed GUARD Model represents a significant step toward addressing the prescription drug affordability crisis affecting millions of Medicare beneficiaries. By incorporating international pricing benchmarks into rebate calculations, this model could help you spend less on the medications you need while maintaining access to quality care. Although implementation wouldn’t begin until 2027 and would initially apply only to selected geographic areas, the model’s outcomes could shape Medicare drug pricing policy for years to come.
These proposed changes could directly impact your wallet and your access to essential medications, making it critical to stay ahead of program developments and understand your current coverage. With so much at stake, working with a knowledgeable advisor ensures you’re positioned to take full advantage of every savings opportunity available to you. For more information about Medicare Part D, please call 866-633-4427 to speak with a Senior Healthcare Solutions Medicare expert.



