ARTICLE
19 December 2025

Understanding The GENEROUS Model In Six Infographics

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Manatt, Phelps & Phillips LLP

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With the Centers for Medicare & Medicaid Services' (CMS) announcement of the GENEROUS Model, life science companies, states and other stakeholders...
United States Food, Drugs, Healthcare, Life Sciences
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Manatt Health recently hosted a webinar on the GENEROUS Model and the implications for life scienece companies, states and patients. Below, we highlight key elements, timing and considerations of the Model. For our full analysis, click here to watch the webinar and receive CLE credit.

With the Centers for Medicare & Medicaid Services' (CMS) announcement of the GENEROUS Model, life science companies, states and other stakeholders are seeking to understand:

  • MFN pricing metrics and how they compare to those previously used by CMS
  • Opportunities and risks of applying and participating for both pharmaceutical manufacturers and state Medicaid programs
  • Outstanding questions on the model's design

Below, we provide an overview of answers to these questions. Our full analysis and advice can be found on the webinar.

Overview

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Key Elements

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Timeline

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Key Differences Between MFN and GENEROUS Model

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Considerations for Manufacturers

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Considerations for States

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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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