Federal Register: DOL EBSA (ERISA) · November 2, 2026 · Primary source
Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure
Summary
The Department of Labor issued a final rule requiring pharmacy benefit managers and affiliated brokers and consultants to disclose direct and indirect compensation to fiduciaries of large, self-insured ERISA group health plans. The rule implements ERISA section 408(b)(2) prohibited transaction exemption disclosure requirements and was directed by Executive Order 14273. It is intended to allow plan fiduciaries to assess the reasonableness of PBM contracts and compensation arrangements. The rule applies to sponsors and fiduciaries of large, self-insured group health plans and certain service providers to those plans.
What this may mean
PBMs and affiliated brokers and consultants serving large, self-insured ERISA group health plans must now disclose their direct and indirect compensation to plan fiduciaries. Plan fiduciaries that fail to obtain required disclosures risk losing the ERISA section 408(b)(2) prohibited transaction exemption for those service arrangements. Health plan sponsors acting as fiduciaries face new due-diligence obligations in contracting with PBMs.
Informational only. Not legal, medical, financial, or other professional advice. Always consult a qualified professional familiar with your specific facts before relying on any item.
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