They sound alike, and they both start with M…but they aren’t the same policy.
Most Favored Nation, or MFN, is an approach that references prices in other countries.
Maximum Fair Price, or MFP, is the negotiated price under a Medicare program created by Congress.
The difference matters because their direct effects on infusion-provider reimbursement are not the same.
What is the difference?
One term to know: Average Sales Price (ASP) is the price measure Medicare generally uses to reimburse most separately payable Part B drugs: ASP + 6%, before sequestration.
| MFN / GLOBE | MDPNP / MFP |
|---|---|
| WHAT IT MEANS Most-Favored-Nation (MFN) pricing compares U.S. drug prices with prices in selected countries. The Global Benchmark for Efficient Drug Pricing Model, or GLOBE, is one Medicare Part B model using this approach. | WHAT IT MEANS The Medicare Drug Price Negotiation Program (MDPNP) was created by the 2022 Inflation Reduction Act. Its negotiated drug price is called a Maximum Fair Price (MFP). |
| HOW IT WORKS Under GLOBE, Medicare uses drug prices in other countries to set a benchmark for how much the government should pay for the same drug after manufacturer rebates. Rather than directly reducing payments to infusion providers, the model collects savings from manufacturers. Infusion providers continue to be reimbursed based on Average Sales Price (ASP). GLOBE launches on January 1, 2027, with patient coinsurance adjustments beginning April 1, 2027. The model’s performance period ends March 31, 2032. | HOW IT WORKS Through MDPNP, CMS negotiates a Maximum Fair Price (MFP) for certain Medicare drugs. Negotiated prices first took effect for Part D drugs in 2026, with selected Part B drugs scheduled to take effect on January 1, 2028. For those Part B drugs, Medicare will reimburse infusion providers based on MFP plus 6%, rather than the traditional Average Sales Price (ASP) plus 6%. Because the add-on payment is calculated using the lower negotiated price, providers could receive significantly less reimbursement even though the operational costs and financial risks of administering these treatments remain unchanged. |
| WHAT HAPPENS TO PROVIDER REIMBURSEMENT GLOBE does not directly replace ASP-based Part B payment. If patient coinsurance falls, Medicare increases its portion so the provider receives the full allowed payment. | WHAT HAPPENS TO PROVIDER REIMBURSEMENT For selected Part B drugs, the standard reimbursement formula will change from ASP + 6% to MFP + 6%. Because the 6% add-on will be calculated using the lower negotiated price, providers will receive a smaller dollar add-on payment. |
| WHAT NICA IS WATCHING While GLOBE does not directly reduce provider reimbursement, NICA will continue monitoring whether it leads to changes in drug prices or increased white bagging requirements that could negatively affect infusion providers and delay patient care. | WHY NICA IS CONCERNED The cost of staffing, storing, and administering an infusion doesn’t decrease just because a drug’s price does. But under MFP, providers receive a smaller add-on payment, which typically helps to cover those costs. Negotiated prices can also drive down ASP, potentially reducing reimbursement from Medicare Advantage and commercial insurers. These financial pressures could force infusion centers to stop offering certain treatments, putting patient access at risk. |
| WHERE THINGS STAND CMS has finalized GLOBE, and the model is scheduled to begin in 2027. Because the final model preserves ASP-based provider reimbursement, NICA believes the direct threat to infusion providers has been mitigated, compared to earlier MFN proposals. We will continue monitoring its implementation for any unintended impacts on infusion providers and patient access, as well as any attempts by Congress to codify MFN policies. | WHAT NICA IS DOING The MDPNP is already law, and reimbursement changes for selected Medicare Part B drugs take effect in 2028. NICA is advocating for the Protecting Patient Access to Cancer and Complex Therapies Act (PACTA), which would preserve ASP-based reimbursement for providers while allowing Medicare and patients to benefit from negotiated drug prices. |
Why do I keep hearing about MFN in the news?
You’ve probably seen headlines about the Trump administration reaching agreements with pharmaceutical manufacturers to lower drug prices in the United States. These agreements are part of a broader push for Most-Favored-Nation (MFN) pricing, which aims to bring U.S. drug prices closer to the lower prices paid in other developed countries.
The confusion is that MFN isn’t one single program. In addition to individual agreements with drug manufacturers, CMS has introduced three separate pricing models that use international drug prices in different ways:
- GENEROUS: A voluntary program where participating manufacturers provide additional rebates to state Medicaid programs based on international drug prices.
- GLOBE: A Medicare Part B model that uses international drug prices to determine rebates manufacturers must pay Medicare, without directly changing how infusion providers are reimbursed.
- GUARD (proposed): A Medicare Part D model that would use international drug prices to calculate rebates manufacturers owe Medicare for certain prescription drugs. Unlike GLOBE, it focuses on Part D rather than Part B.
Importantly, the final GLOBE model is much narrower than originally proposed. CMS excluded additional categories of drugs and plans to exempt manufacturers participating in GENEROUS. As a result, CMS estimates that as few as four manufacturers may ultimately be subject to GLOBE, although that could change.
So what does this mean for infusion providers? While MFN continues to make headlines, the current GLOBE model preserves ASP-based provider reimbursement. That is different from the Medicare Drug Price Negotiation Program (MDPNP), which was established by Congress in 2022 and will change the reimbursement formula for selected Medicare Part B drugs beginning in 2028. That distinction is why NICA is focusing its advocacy efforts on protecting providers from the reimbursement impacts of MDPNP through PACTA.
Two different histories
| MFN / GLOBE | MDPNP / MFP |
|---|---|
| 2020–22 A Medicare MFN model sought to tie Part B payment to international prices; it was blocked and later withdrawn. | 2022 Congress enacted the Inflation Reduction Act, creating the MDPNP. |
| 2025 The administration revived MFN through an executive order and manufacturer agreements; CMS proposed GLOBE. | 2026 The first negotiated Part D prices took effect January 1. |
| 2026 GENEROUS began as a voluntary Medicaid model. CMS finalized GLOBE with added exclusions and planned manufacturer waivers. | 2026 CMS selected 15 drugs for the 2028 cycle, including Part B therapies such as Entyvio, Orencia, Xolair, and Cosentyx. |
| 2027 GLOBE starts January 1; payment and coinsurance adjustments begin April 1. | 2028 The first negotiated prices for selected Part B drugs take effect January 1. |
Where NICA stands, and what NICA has done
On MFN and GLOBE
NICA opposed earlier MFN policies that could threaten infusion-provider reimbursement and patient access. In February 2026, NICA urged CMS to withdraw GLOBE, while acknowledging its improvement over earlier models: it did not directly change ASP-based payment. We raised concerns about white bagging, indirect ASP effects, and access. The final rule further narrowed GLOBE. NICA does not endorse the model and will monitor implementation, but currently sees a less direct reimbursement threat than other policies, such as MDPNP/MFP.
On MDPNP, MFP, and PACTA
• Regulatory advocacy: Commented to CMS in 2025 and 2026 on MFP implementation, ASP, and practice operations.
• Provider evidence: Supported a 2025 Avalere survey of 304 providers and commissioned Milliman’s 2026 analysis, projecting $9.2 billion less non-oncology Part B provider reimbursement over 2028–2037 under current law.
• Congressional advocacy: Hosted federal Hill Days advocating for PACTA’s passage (2024 – 2026); met with Senate Finance offices in June 2026; mobilized grassroots advocates; and remain active members of the PACT Coalition.
What Can NICA and Infusion Providers Do?
The Medicare Drug Price Negotiation Program (MDPNP) is the direct reimbursement issue. For selected Part B drugs in 2028, a move from ASP to MFP means a smaller dollar add-on (the 6% will be based on the lower MFP rather than ASP), even as practices bear the same costs of acquiring, preparing, and administering treatment.
The Protecting Patient Access to Cancer and Complex Therapies Act (PACTA, H.R. 4299) would take providers out of the middle of the MDPNP drug negotiations. Under PACTA, CMS would continue selecting drugs and negotiating a Maximum Fair Price (MFP), but providers would continue receiving reimbursement based on Average Sales Price (ASP) + 6%, protecting the add-on payments they rely on to administer these treatments.
Rather than reducing provider reimbursement to achieve savings, drug manufacturers would make direct payments to Medicare reflecting the difference between ASP-based and MFP-based reimbursement amounts. Patients would still benefit from lower cost-sharing based on the MFP.
PACTA would also exclude MFP from ASP calculations, helping protect reimbursement rates under Medicare Advantage and commercial insurance contracts tied to ASP.
| Take action: Ask Congress to support PACTAInfusion providers can tell their lawmakers to act before Part B MFPs take effect in 2028 using either of NICA’s Advocacy Campaigns: Contact Congress about PACTA | Take another PACTA action |
Learn more
CMS: GLOBE • CMS: GENEROUS • CMS: Historical MFN Model • CMS: Selected Drugs • CMS: GUARD
NICA: What Is PACTA? • Avalere: Provider Survey • Milliman: Part B Impact • PACT Coalition • H.R. 4299
