Can the plan audit the PBM?
The Department says the rule lets fiduciaries audit the accuracy of PBM disclosures. The law-firm summary reports an annual audit at the plan’s written request.
Audit rights
The Department of Labor says the rule lets plan fiduciaries audit the accuracy of PBM disclosures and gives additional relief if a PBM fails to meet its obligations. The law-firm summary reports an audit at least once a year at the plan’s written request, with the fiduciary selecting the auditor.
An audit right is only useful if someone owns it. Decide who reviews the disclosures and when, and document it.
Where to go from here
Select and monitor service providers
A documented process for choosing and reviewing plan vendors.
Put reviews on a calendar
When to review each provider.
Send us your renewal
Share the renewal and plan documents and we will tell you what to test.
More questions on this topic
Does this rule apply to my plan?
It is reported to apply to self-insured plans of larger employers, with a threshold of 100 employees or participants, and not to the detailed requirements for fully insured plans.
When do the disclosures start?
The applicability date is reported as plan years beginning on or after July 1, 2027.
What will the PBM have to disclose?
According to the Department of Labor: rebates and other manufacturer payments, compensation when the plan’s price exceeds the pharmacy’s reimbursement, and payments recouped from pharmacies.
Where these details come from.
Details are from the Department of Labor’s announcement, the Federal Register entry and a law-firm summary, as of publication. Check the rule text for dates and thresholds.
- U.S. Department of Labor: news release on the final PBM transparency rule, October 29, 2026
- Federal Register: Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure, November 2, 2026
- Consumer Financial Services Law Monitor: DOL final rule expands PBM transparency for self-insured health plans
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.