"The proposed regulations reflect the DOL's position that group health plan fiduciaries have a duty to ensure the reasonableness of fees and that transparent fee disclosures should help them to evaluate PBM arrangements. ... [T]he DOL recognizes that negotiating PBM arrangements requires specialized expertise, and that most group health plans must work with benefits consultants or brokers who may have conflicts of interest due to payments or rebates they receive from PBMs. The proposed regulations ... do not provide guidance on how fiduciaries can use [the disclosures] to negotiate more favorable prescription drug prices."  MORE >>