Excerpt: On February 4, 2010, the DOL added two FAQs to the supplemental FAQs issued last year; they specifically address whether certain direct and indirect compensation earned by PBMs is reportable for Schedule C purposes. While the guidance reiterates DOL's previously-articulated position that PBMs generally would be considered plan service providers subject to Schedule C reporting, DOL nonetheless announced substantial, though potentially temporary, reporting relief for some forms of indirect compensation earned by PBMs, including rebate and discount revenue.