The DOL’s New PBM Fee Disclosure Rule: What Fiduciaries Need to Know

Trucker Huss

Prescription drug spending is one of the fastest-growing components of group health plan costs, yet the compensation that pharmacy benefit managers (PBMs) receive has long been nearly impossible for plan fiduciaries to see and understand. The Department of Labor (DOL) has sought to change this with a new final rule aimed at improving transparency of PBM fees and compensation.

In this session, Mary Powell and Sarah Kanter will explain what the new disclosure rule requires and offer practical guidance on the following topics:

• An  overview of the DOL’s PBM fee disclosure rule’s requirements

• What PBMs must disclose, including direct and indirect compensation such as rebates, spread pricing, and other manufacturer-derived revenue

• Timing, format, and content of required disclosures, and the consequences of a PBM’s failure to comply

• Fiduciary responsibilities for reviewing PBM disclosures and assessing the reasonableness of PBM compensation

• How the new rules interact with the fee disclosure rules under the Consolidated Appropriations Act, 2026

• How the new rule will affect requests for proposals (RFPs), contract negotiations, and renewals

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