CMS Finalizes the GLOBE Model: What It Means for Infusion Providers and Physician Practices

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Tue, Oct 13, 2026

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On September 30, 2026, the Centers for Medicare & Medicaid Services (CMS) finalized the Global Benchmark for Efficient Drug Pricing (GLOBE) Model, a new Medicare Part B model affecting certain high-cost drugs. Although the model is directed primarily at drug manufacturers, it will have practical consequences for physician practices, infusion providers, and other providers that administer and bill for Part B drugs.

The most important point for providers is that GLOBE does not reduce the Medicare payment for an affected drug. Providers are not participants in the model and are not responsible for the new manufacturer rebates. Instead, the model may reduce the coinsurance owed by certain Original Medicare patients for certain drugs. For providers, the main issue is therefore not a reduction in reimbursement, but how patient responsibility is calculated, collected, and reconciled.

Under ordinary Medicare Part B rules, a beneficiary generally pays 20% of the applicable amount for a covered drug. Under GLOBE, certain eligible patients may have a lower coinsurance percentage. For example, if the Medicare allowed amount for an infusion drug is $10,000, a patient ordinarily could owe $2,000. If the GLOBE calculation reduces the patient’s coinsurance to 10%, the patient would owe $1,000 and Medicare would pay $9,000. The provider still receives the full $10,000 allowed amount.

For an infusion practice, this can have a meaningful financial effect. A lower patient responsibility may reduce unpaid balances and collection costs. At the same time, practices that collect patient responsibility before Medicare processes a claim will need to account for the possibility that the amount initially collected is higher than the patient’s final responsibility. For example, a practice that collects $2,000 in advance based on a 20% estimate could later learn that the patient’s actual responsibility was $1,000. The practice would then need to reconcile the claim and address the excess payment.

Not Every Patient or Drug Is Affected

GLOBE applies only to certain high-spending single-source drugs and biological products and includes several exclusions. It also applies only to certain Original Medicare beneficiaries. Medicare Advantage patients are not included in the model. The model’s geographic component is particularly important for providers. CMS selected geographic areas covering approximately 25% of Original Medicare Part B beneficiaries. As a result, GLOBE follows the patient, not the provider. A practice could treat two Medicare patients receiving the same drug on the same day, while only one patient’s claim is subject to the GLOBE coinsurance calculation. Providers do not need to independently calculate the GLOBE amount. CMS will determine the applicable beneficiary coinsurance through the Medicare claims process. The practical concern is making sure the practice’s existing billing and patient-financial workflows properly reflect the amount ultimately determined by Medicare.

What Should Practices Do Now?

Practices that administer expensive Part B drugs should first determine whether they are likely to have meaningful GLOBE exposure. Once CMS publishes the applicable geographic areas and drug list, providers should compare them with the drugs they administer and the patients they serve. Practices with significant oncology, immunology, rheumatology, ophthalmology, or other high-cost Part B drug volume should pay particular attention.

Practices should also speak with their billing and practice-management vendors about how GLOBE claims will be processed and how the applicable patient responsibility will appear on Medicare remittance information and patient statements. The objective is not necessarily to create a separate GLOBE billing system, but to make sure existing systems do not automatically apply the standard 20% coinsurance when a lower amount applies.

Finally, practices should review how they estimate and collect patient responsibility before claims are adjudicated. Financial counseling staff should be prepared to explain why some patients may owe less than 20% and why two patients receiving the same drug may have different responsibilities. Practices should also have a process for identifying and correcting overcollections after Medicare processes the claim.

The Bottom Line

GLOBE is primarily a manufacturer pricing model, but providers will experience its effects through their patients. The Medicare payment to the provider does not decrease. The patient’s share of that payment may. For infusion providers and physician practices, the key questions are whether they administer affected drugs, whether their patients fall within the selected geographic areas, and whether their existing billing and collection processes can handle a lower patient responsibility. The model begins on January 1, 2027, with the first performance year and the associated beneficiary coinsurance changes beginning April 1, 2027. Practices administering high-cost Part B drugs should use the intervening period to identify their potential exposure, coordinate with billing vendors, and review their patient-collection procedures.

MDRXLaw represents physician practices, infusion providers, pharmacies, laboratories, and other healthcare businesses in Medicare and Medicaid reimbursement, payor disputes, audit defense, regulatory compliance, and licensing matters. If your practice administers high-cost Medicare Part B drugs, contact our attorneys at 212.668.0200 or info@mdrxlaw.com to discuss how the GLOBE Model may affect your patients and your reimbursement operations.

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