The US Centers for Medicare and Medicaid Services (CMS) announced that it will use leading intelligence and productivity platform GlobalData‘s POLI database to verify prices in the reference countries and set maximum prices for prescription drugs under two Medicare price models based on International Reference Pricing (IRP).
The two models, announced in late December 2025, seek to implement President Donald Trump’s Most Favored Nation (MFN) drug pricing agenda and will be mandatory for pharmaceutical companies. The Global Benchmark for Efficient Drug Pricing (GLOBE) price mechanism is due to start in October 2026 and will apply to Medicare Part B medicines. The second model, Guarding U.S. Medicare Against Rising Drug Costs (GUARD) will apply to Medicare Part D drugs and is set to launch in January 2027.
Under the two models, there are two options for price referencing. Option one is to cap the price in the US at the level of the lowest official list price of the same product among the reference countries selected by the US. Alternatively, if the manufacturer discloses the confidential net prices agreed with the other countries to the CMS, the price will be capped at the average among the reference countries.
The list of countries that the US plans to reference under GLOBE and GUARD comprises: Australia, Austria, Belgium, Canada, the Czech Republic, Denmark, France, Germany, Ireland, Israel, Italy, Japan, the Netherlands, Norway, South Korea, Spain, Sweden, Switzerland, and the UK. The list of reference countries confirmed by the CMS in December matches precisely the list of markets that was predicted by GlobalData in May, after applying an adjustment by purchasing power parities (PPP) to derive a final list of reference countries for the US.
Floriane Reinaud, Senior Director of Databases and Analysis at GlobalData, comments: “The POLI service was a pioneer when it comes to drug prices. Our market expertise has allowed us to identify reliable and official sources in each market and to understand wholesale and pharmacy margins in order to estimate different price types. Later, we created our own market indicators including time to pricing, time to reimbursement or time to HTA, average price changes over time, number of molecules eligible for reimbursement. These molecules are highly used for countries’ benchmarking. Having worked on that field for so many years, I’m proud of the different evolutions the POLI platform has undergone and how easy it makes it to benchmark prices across different countries.”
Milena Izmirlieva, Senior Director and Head of Health Economics and Market Access Research and Analysis at GlobalData, adds: “It should not come as a surprise that POLI has been selected as a price source by the CMS. IRP price calculations normally use list prices, and it is uncertain if the CMS offer of a more favourable IRP formula is enough to incentivize pharmaceutical companies to disclose confidential net prices. The POLI database has been around since 2007, setting a gold standard for pricing data and providing the longest-running source of list prices. Having the historical prices allows pharmaceutical companies and payers alike to assess the impact on prices of implemented reforms and to forecast the impact of planned reforms.”
Additionally, the pricing data available in POLI is overlaid with proprietary analysis that links specific pharmaceutical price movements to a particular reform, indication approval, or reimbursement decision at the country level for the particular medicine.
IRP, which is what the MFN policy aims to implement in the US, is a particular area of expertise for GlobalData. IRP reforms around the world are tracked on a daily basis, and every aspect of a country’s IRP system is examined in detailed IRP 360 country profiles and strategic reports.
Izmirlieva continues: “The combination of POLI data and in-depth knowledge of the IRP rules means that the GlobalData team is uniquely positioned to explain past price impacts, but also – crucially – to predict the impact of IRP reforms.”
In 2025, GlobalData produced four IRP-focused strategic reports, two of which are focused on the US MFN plans:
- Critical Assessment of Trump Administration’s Renewed Efforts to Introduce IRP in the US via the MFN Executive Order examines how the initial IRP plans disclosed in the May 2025 executive order align with the international experience with IRP.
- Paraguay and Panama Update Drug Pricing Methodology and Advance Towards International Reference Pricing examines IRP regulations in two Latin America markets which introduced IRP as a pharmaceutical cost-containment tool in 2024.
- Industry Scores a Win as Watered-Down Version of Canada’s IRP Reform Unveiled in Final Guidelines, but Prices Will Nevertheless Decline provides insights into how Canadian authorities amended their plans for IRP reform, following industry pushback.
- Evaluating the Trump Administration’s New MFN Medicaid GENEROUS Model assesses the implications of a separate model for Medicaid drugs based on MFN in the US, which was launched in January 2026, called the GENErating cost Reductions for U.S. Medicaid (GENEROUS) model.
Izmirlieva concludes: “IRP is one of the most widely used price control mechanisms for medicines. Understanding the details of the IRP mechanism of each country and how it evolves over time, is essential for forecasting pharmaceutical prices. POLI pricing data and other relevant indicators from POLI – such as a country’s place in launch sequencing – are important for policymakers and for pharmaceutical companies, particularly because the effects of IRP are not limited to the market undertaking the reform but also affect prices and access to medicines in other countries.”
GlobalData has many years of experience in drug pricing and IRP analysis. The POLI database provides pricing data, along with reimbursement outcomes and health technology assessments, for more than 80 countries around the world. It is accessible on a subscription-only basis. To request access to the POLI database, please reach out to: https://marketaccess.globaldata.com/contact-us/.
