As a member of the Partnership for Part D Coalition, AAPP supported a letter to CMS in opposition to the GUARD model. Opposition centers around the anticipated weaking of the 6 protected classes protections through its proposed Medicare drug pricing changes, which could lead to worsening patient health outcomes and increased costs. Additionally, the model is anticipated to increase costs to patients (based on the economic analysis in the proposed rule, stating that it will cause an increase of $3.6B in out-of-pocket costs), worsen already-declining access to medications by undercutting incentives for innovation in areas of high unmet need, worsen perceived “deficits of care” faced by patients taking 6 protected class drugs, and import other countries’ rationing approach to coverage.