"Plan sponsors and PBMs should anticipate that the DOL's final rule may be significantly revised to coordinate with CAA 2026's requirements. In particular, the DOL may need to reconsider its proposed July 1, 2026 applicability date, given that CAA 2026 does not take effect until January 1, 2029 for calendar-year plans, creating a potential gap period during which the DOL's more limited disclosure requirements would apply to self-insured ERISA plans before the broader CAA 2026 mandates take effect ... [A table] compares key elements of CAA 2026 and the DOL Proposed Rules."  MORE >>