"The Proposed Rule attempts to provide ... transparency by: [1] Requiring PBMs to provide written disclosures of the PBM's direct and indirect compensation ... reasonably in advance of entering into or renewing a service arrangement ... [2] Establishing audit provisions designed to ensure that plan fiduciaries can verify the accuracy of the disclosures; and [2] Providing relief for plan fiduciaries if the PBM fails to meet its disclosure obligations.... [T]he Proposed Rule would require PBMs to disclose compensation as a monetary amount (even if estimated), rather than providing formulas, which are notoriously difficult for fiduciaries to assess when evaluating reasonableness."  MORE >>