The applicability date is reported as plan years beginning on or after July 1, 2027. A good-faith enforcement policy is reported to run until then, so the questions are worth asking now.
According to the law-firm summary, the rule becomes effective 60 days after Federal Register publication, with an applicability date for plan years beginning on or after July 1, 2027. It also reports a good-faith enforcement policy running from February 3, 2026 through the applicability date.
A plan year that begins on or after July 1, 2027 is the first covered year. Employers with earlier plan years have time, and the questions can be asked at the next renewal.
When to review each provider.
What a fiduciary should be able to answer about a pharmacy contract.
Share the renewal and plan documents and we will tell you what to test.
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.
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 Department says the rule lets fiduciaries audit the accuracy of PBM disclosures.
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.
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.