In mid-April 2026, a bipartisan coalition of 45 State Attorneys General (AG) submitted a formal letter to the U.S. Department of Labor (DOL) expressing their collective support for a proposed rule (Improving Transparency into Pharmacy Benefit Manager Fee Disclosure, or RIN 1210-AB37). If enacted as drafted, the rule will require pharmacy benefit managers (PBM) to disclose their compensation arrangements to plan sponsors as a condition of satisfying the “reasonableness” requirement of ERISA’s prohibited transaction exemption — effectively embedding fee transparency into routine pharmacy benefit manager (PBM) contracting procedures. Click here to continue reading the full version of this alert.
Bipartisan Coalition of State AGs Backs Federal PBM Transparency Rule