CCAGW Urges Senate to Oppose the CMMI Models That Use MFN Pricing
Letters to Officials
October 28, 2025
Dear Senator,
On behalf of the more than one million members and supporters of the Council for Citizens Against Government Waste (CCAGW), I urge you to oppose any effort to use the Center for Medicare and Medicaid Innovation (CMMI) to create and test any model that includes most favored nation (MFN) pricing. Doing so would combine a failed agency with bad policy, increase government control over healthcare, and do nothing to improve care quality or affordability for America’s seniors and individuals with disabilities.
CCAGW is especially concerned about drug payment models for CMMI to test MFN that are currently being considered by the Office of Management and Budget. While details about these models have not been revealed, if they are approved despite strong opposition, they should be limited in scope rather than being mandatory and forcing the use of MFN nationwide.
CCAGW has expressed its concerns about CMMI in an October 9, 2025, coalition letter to the House and Senate. The letter noted that CMMI was created in the Affordable Care Act with a $10 billion-per-decade mandatory budget and that the Congressional Budget Office (CBO) estimated that CMMI would save $2.8 billion from 2011-2020. Instead, it cost $5.4 billion during that period and is projected to cost another $1.3 billion between 2021 and 2030. From 2011-2020, only four of the 49 models, or eight percent, showed enough potential to save money and improve care.
Members of Congress agree that CMMI is a failed program. At the June 13, 2024, House Energy and Commerce Committee Health Subcommittee hearing, Committee Chair Cathy McMorris Rodgers (R-Wash.) said that CMMI “has little to show in demonstrated outcomes” and that she has “a hard time believing any objective observer could look at the results thus far and describe CMMI as a success.” Rep. Bob Latta (R-Ohio) cited concerns by providers and stakeholders “about the complexity, administrative burden and perceived lack of transparency involved when participating in the CMMI models.”
CCAGW has repeatedly cited the dangers of price controls on pharmaceuticals and other products. MFN imports foreign prices from countries with socialized healthcare and fails to resolve issues related to foreign freeloading in trade negotiations. MFN also undermines innovation and harms U.S. competitiveness. An August 11, 2020, letter signed by 83 organizations noted that President Trump’s MFN executive order in his first term would “result in the same negative outcomes to our healthcare system as those overseas – less medical innovation leading to fewer cures and healthcare shortages for American patients.”
Members of Congress agree that MFN is bad policy. A July 14, 2025, letter signed by 18 representatives noted, “price setting policies that other countries frequently adopt both undervalue medicines in the non-U.S. market and ultimately make life-saving therapies more expensive for U.S. patients. … the U.S. should not be forced to subsidize medicine costs for the rest of the world at the expense of American patients.” A July 18, 2025, letter signed by 33 senators, including seven members of the Senate Committee on Health, Education, Labor and Pensions, expressed their support for confronting “these longstanding and unfair price controls that leave Americans disproportionately funding global health care innovation. Eliminating these egregious practices could increase investment in medical research and development by billions of dollars and lower overall health care costs for Americans.”
Concerns about CMMI are not limited to CCAGW, its coalition partners, and members of Congress. On October 22, 2025, CCAGW released the results of a national poll of 1,600 voters. The results showed that voters want Congress to eliminate bureaucratic waste at CMMI. The poll found that 61 percent of voters want CMMI models that fail to generate savings eliminated and only 29 percent believe spending $10 billion per decade on CMMI is a smart use of taxpayer dollars. More than 75 percent of voters are concerned that CMMI increases government interference over personal healthcare decisions and agree that Congress should establish safeguards to protect patients from mandatory policy changes.
CCAGW urges you to act now to reevaluate funding of CMMI and consider whether it should be eliminated altogether or, at a minimum, should be subjected to safeguards that prevent it from imposing sweeping, intrusive policy changes like government price controls through MFN.
CCAGW appreciates your consideration of our concerns over CMMI’s record of failure, the pitfalls of price controls, and the dangers to taxpayers, patients, innovation, and U.S. global leadership in healthcare that would result from combining CMMI and MFN.
Sincerely,
Tom Schatz
President, CCAGW