New PBM Reform Rules May Reshape Employer Health Plan Oversight

A new Ogletree Deakins article outlines how the Consolidated Appropriations Act of 2026 (CAA 2026) could significantly expand transparency, disclosure, and audit requirements for pharmacy benefit managers (PBMs) and employer-sponsored health plans. The legislation introduces new rebate pass-through requirements, compensation disclosures, employer audit rights, and participant notice obligations that may reshape how employers oversee pharmacy benefit arrangements moving forward. Employers negotiating PBM contracts or evaluating fiduciary oversight processes should closely monitor these evolving compliance requirements.