"ERIC continues to support congressional efforts to designate that vendors involved in critical plan design and administration decisions, including an entity providing pharmacy benefit management services, are fiduciaries within the meaning of section 3(21) of ERISA with respect to a group health plan or group health insurance coverage.... Transparency is needed regarding PBM compensation sources.... There are multiple frameworks and standards that health plan sponsors and ERISA fiduciaries already comply with and use to protect sensitive plan and participant data.... The introduction of new or broadened requirements under ERISA would be redundant and would contribute to further complexity and administrative costs."

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