Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure
Published Date: 1/30/2026
Proposed Rule
Summary
The Department of Labor wants pharmacy benefit managers (PBMs) and related service providers to clearly share how much they get paid with the people managing self-insured health plans. This helps plan managers make sure fees are fair and transparent. If finalized, this rule will affect health plan sponsors and PBMs, with comments open until March 31, 2026.
Analyzed Economic Effects
2 provisions identified: 1 benefits, 1 costs, 0 mixed.
PBMs Must Disclose All Fees
The rule would require pharmacy benefit managers (PBMs) and affiliated brokers and consultants to give fiduciaries of ERISA-covered self-insured group health plans clear disclosures of their direct and indirect compensation, including advance disclosure of compensation they reasonably expect to receive. These disclosures are meant to help plan sponsors and other responsible plan fiduciaries assess whether contracts and fees are reasonable.
New Audit and Verification Duties
The proposal includes audit provisions that would let responsible plan fiduciaries verify the accuracy of PBM and affiliated provider disclosures. That means PBMs and affiliated brokers/consultants could face new compliance, record-sharing, and audit obligations when they contract with ERISA-covered self-insured group health plans.
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Key Dates
Department and Agencies
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