Arnold Ventures Submitted Comments to Administrator Oz on the Guarding U.S. Medicare Against Rising Drug Costs (GUARD) Model

In comments to the Centers for Medicare and Medicaid Services (CMS) Arnold Ventures notes that given the complexity of the Part D program coupled with the limitations of making administrative changes to the Part D inflation rebate established in the IRA, it is unclear whether it is possible for the GUARD Model to lower costs to the federal government without significantly raising costs to beneficiaries and to Medicare Part D plans. For this reason, AV does not support the proposed model.