On Thursday, October 29, 2026, the US Department of Labor finalized a pharmacy benefit manager transparency rule, which is required reading for all employers that sponsor group health plans.
Link to What the Final Rule Requires What the Final Rule Requires
Under the rule, pharmacy benefit managers (PBMs) and their affiliated brokers and consultants must disclose their fees and compensation to certain self-insured group health plans.
With this final rule, employers should gain greater visibility into how much drug manufacturers, pharmacies, and others pay PBMs. Employers can use that information to negotiate contracts and seek lower prescription drug costs for their plans.
Link to What PBMs Must Disclose What PBMs Must Disclose
The final rule requires PBMs to disclose the following information to plan fiduciaries, allowing them to assess the reasonableness of compensation for PBM services and fulfill their duties under ERISA:
- Rebates and other payments from drug manufacturers.
- Compensation received when the price paid by the plan for a prescription drug exceeds the amount reimbursed to the pharmacy.
- Payments recouped from pharmacies in connection with prescription drugs dispensed to plan participants.
The final rule also allows plan fiduciaries to audit the accuracy of PBM disclosures and provides additional relief for plan fiduciaries if a PBM fails to meet its obligations.
Link to What Employers Should Do Now What Employers Should Do Now
All employers are encouraged to work with their brokers and ERISA counsel to understand how the new rule will work, and the compliance steps necessary to document their review of PBMs under ERISA. The rule applies to plan years beginning on or after July 1, 2027.