Labor Department requires pharmacy benefit managers to disclose fees to large self-insured plans
The Labor Department finalized a rule requiring pharmacy benefit managers and their affiliated brokers and consultants to disclose their compensation to fiduciaries of large, self-insured group health plans covered by ERISA. The disclosures include rebates from drug manufacturers, spread pricing between what the plan pays and what the pharmacy receives, and recoupments from pharmacies. The rule takes effect January 4, 2027, and applies only to large self-insured plans.
The disclosures are meant to help plan fiduciaries assess whether their contracts with these service providers are reasonable. Most fully insured plans and small group plans are outside the rule's scope — it affects sponsors and fiduciaries of large self-insured plans and the service providers that work with them.