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.
The new disclosures
The Department of Labor lists three new disclosures: rebates and other payments from drug manufacturers, compensation earned when the plan’s price for a drug exceeds the amount reimbursed to the pharmacy, and payments recouped from pharmacies for drugs dispensed to participants.
The law-firm summary adds that disclosures are reported before an arrangement is entered, extended or renewed, semiannually, and quarterly on request.
What the PBM disclosures help you ask
The Department of Labor’s release describes disclosures about rebates, spread pricing, recoupments, and audit rights. In plain terms, they help a plan see what the pharmacy benefit manager is paid and what it keeps, which was often hard to see before.
A plan fiduciary can use that information to ask specific questions: how much rebate money is passed back, whether the plan pays more than the pharmacy is paid, and what the plan can audit. We help translate the disclosures into a short list of questions for your PBM contract review.
Where to go from here
Ask your PBM contract questions
What a fiduciary should be able to answer about a pharmacy contract.
Know how fee reasonableness is judged
How ERISA section 408(b)(2) applies to fees your plan pays.
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.
Can the plan audit the PBM?
The Department says the rule lets fiduciaries audit the accuracy of PBM disclosures.
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
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