"Key developments include: [1] PBMs treated as 'covered service providers' for purposes of [ERISA] Section 408(b)(2) subject to compensation disclosure requirements. [2] Required 100% rebate and remuneration pass through to ERISA plans, with limited exceptions ... [3] Mandatory semiannual reporting of detailed drug pricing, spread pricing, rebate, and compensation data to group health plans. [4] Civil penalties for noncompliance. [5] A limited 'innocent fiduciary' exception for plan fiduciaries under specified conditions."  MORE >>