Federal reforms are putting plan sponsors’ oversight duties in sharper focus. The 2026 Consolidated Appropriations Act (signed February 3) adds PBM reporting rules that cover drug spending, pass-through rebates, and vendor compensation. Major provisions will generally apply to plan years beginning on or after August 3, 2028 (January 1, 2029 for calendar-year plans) as contracts are entered into, extended, or renewed.
Plan sponsors already have a duty under ERISA to carefully select and monitor plan vendors and ensure compensation is reasonable. A Department of Labor proposal would add to that duty through detailed PBM disclosures before contracts are signed, extended, or renewed, plus semiannual reporting on manufacturer payments, pricing spreads, and formulary incentives.
MedBen Rx already helps put that oversight into practice. Our acquisition cost index (ACI) model starts with what pharmacies pay for medications and returns 100% of paid rebates to the plan. Detailed reporting gives employers a clearer view of drug and administration costs, supporting reviews of vendor compensation and plan performance.
Formulary management adds another review opportunity. MedBen Rx High Value Formulary uses clinical evidence to favor effective therapies, including appropriate generics and biosimilars. Evaluating those choices alongside pricing and rebates helps employers assess pharmacy benefit value and prepare for the new disclosure requirements.