Is this legal advice?
No. We are benefits consultants, not attorneys. Read the final rule and talk to your counsel about your plan’s obligations.
What this page is and is not
No. We are benefits consultants, not attorneys. Our pages summarize public sources and link to them so you can read the rule yourself.
For your plan’s specific obligations, read the final rule and talk to your counsel. We bring the benefits side, including your pharmacy contract and renewal.
Who to consult for legal questions
We are benefits consultants, not attorneys. We summarize public sources so that employers can read the rule themselves and ask better questions. A question about whether a specific contract complies with the rule is a legal question.
For those, speak with benefits or ERISA counsel. We are happy to work with your attorney by supplying the plan documents, the PBM contract terms and a plain-language summary of how the plan operates.
Where to go from here
Ask your PBM contract questions
What a fiduciary should be able to answer about a pharmacy contract.
Consider level-funded and self-funded options
When a different funding arrangement is worth testing.
Send us your renewal
Share the renewal and plan documents and we will tell you what to test.
More questions on this topic
Does the rule apply to my level-funded plan?
It depends on how the plan is structured and its size.
Does the rule apply if I am fully insured?
The law-firm summary reports that fully insured plans are excluded from the detailed requirements.
When should a Michigan employer act?
The reported applicability date is plan years beginning on or after July 1, 2027.
Where these details come from.
Details are from the Michigan DIFS, the Department of Labor’s announcement and a law-firm summary, as of publication. Check the rule text for dates and thresholds.
Send us your renewal.
We’ll tell you whether it looks competitive, where we see opportunity, and the five questions we’d put to your carrier. No cost, and no obligation to move anything.
The renewal letter
Your current plan summary
Contribution split by tier
Enrolled counts by tier
Four documents — two more if your group is 50 or more. Nothing else; every extra one is a reason to postpone.