Partnership Comment Letter to CMS: Withdraw the GUARD Model

On February 26, 2026, the Partnership submitted a comment letter to the Centers for Medicare & Medicaid Services' (CMS) Notice of Proposed Rulemaking (NPRM) for the Guarding U.S. Medicare Against Rising Drug Costs (GUARD) Model, requesting that the agency withdraw the model. The letter provides a history of the six protected classes policy and the bipartisan support it has received in Congress. It also highlights the benefits it provides patients and outlines the Partnership's concerns about the model, specifically that it will weaken the six protected classes policy, raise beneficiary costs, disincentivize innovation, worsen "deficits of care," and import foreign approaches to coverage.

Read the full letter.