"If finalized, the proposed regulations could significantly alter how employer health plans evaluate PBM arrangements.... Plan fiduciaries would have greater access to data necessary to assess whether PBM compensation is reasonable and whether PBM arrangements present conflicts of interest.... The new disclosure regime may affect contract negotiations, particularly regarding rebate pass-through structures, spread pricing arrangements, and audit rights and reporting obligations.... Greater transparency could increase litigation risk where PBM compensation appears excessive or inconsistent with fiduciary duties under ERISA."  MORE >>