PFCD Statement on the GENEROUS Model: Importing Foreign Pricing Models is Not the Answer

Nov. 12, 2025 (WASHINGTON, D.C.) The Partnership to Fight Chronic Disease (PFCD) released the following statement in response to the Centers for Medicare & Medicaid Services’ (CMS) announcement of a new demonstration through the CMS Innovation Center, the GENErating cost Reductions fOr US Medicaid (GENEROUS) Model:

“Given PFCD’s well-documented opposition to importing foreign price controls, we have strong concerns about CMS’s proposed GENEROUS Model, which would tie Medicaid prescription drug pricing to foreign ‘Most Favored Nation’ (MFN) benchmarks. Adopting prices from foreign countries means adopting the discriminatory cost-effectiveness standards those countries use to set prices and determine patient access, including the Quality-Adjusted Life Year (QALY). Each of the eight countries this model will use to calculate the MFN price —  the United Kingdom, France, Germany, Italy, Canada, Japan, Denmark, and Switzerland —  use QALYs to inform coverage and pricing decisions. The QALY-based frameworks used in these nations have frequently led to treatment delays and care rationing for vulnerable populations, including older adults, individuals with disabilities, families navigating rare diseases and those with multiple chronic diseases. The adoption of such a strategy prioritizes government savings at the expense of patient-centered care and may, in fact, worsen access for Medicaid beneficiaries who already pay little or no cost-sharing for their medicines.

“As the Trump administration continues to pursue MFN drug pricing proposals, we remain concerned about the impact these policies will have on people living with one or more chronic conditions. MFN poses a significant risk to patient access to prescribed treatments in the short-term and future innovations down the road. The adoption of foreign price controls will only serve to undermine the progress achieved through American medical research and erode incentives for developing the next generation of therapies and cures here in the U.S.

“PFCD has long supported the goal of improving affordability for people living with chronic disease, but we urge policymakers to reject foreign pricing models that will not meaningfully improve patient affordability or access.”