ITIF：2026年对卫生与公众服务部关于拟议的GUARD模式的评论报告（英文版）

The Information Technology and Innovation Foundation (ITIF) is pleased to submit the following comments in response to the Centers for Medicare & Medicaid Services’ (CMS) proposed Guarding U.S. Medicare Against Rising Drug Costs (GUARD) model. ITIF is an independent, nonprofit, nonpartisan research and educational institute focusing on the intersection of technological innovation and public policy. ITIF believes the international reference pricing approach envisioned in the GUARD model is