US Department of Labor finalizes pharmacy benefit manager transparency rule, delivering big win for American workers, families

The Department of Labor's Employee Benefits Security Administration finalized a rule requiring pharmacy benefit managers and their affiliated brokers and consultants to disclose fees and compensation to large employers' self-insured group health plans. The rule implements transparency reforms enacted in the Consolidated Appropriations Act, 2026, and is issued under ERISA's statutory service provider prohibited transaction exemption. The rule covers employer-sponsored self-insured group health plans that collectively cover approximately 90 million Americans. The final rule mandates disclosure of three specific categories of compensation: rebates and other payments received from drug manufacturers; compensation received when the price paid by the plan for a prescription drug exceeds the amount reimbursed to the pharmacy; and payments recouped from pharmacies in connection with prescription drugs dispensed to plan participants. These disclosures are directed to plan fiduciaries to allow them to assess the reasonableness of PBM compensation and fulfill their duties under ERISA. The rule also grants plan fiduciaries the right to audit the accuracy of PBM disclosures and provides additional relief for plan fiduciaries when a PBM fails to meet its disclosure obligations. The rule further provides compliance-assistance information for all service providers to employer-sponsored group health plans, which are now required to report fees and compensation to group health plan fiduciaries under the Consolidated Appropriations Act, 2026. The Department projects the final rule will lower prescription drug costs for health plans and participants by as much as $22 billion on an undiscounted basis over 10 years.