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Free Publications
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New PBM Disclosure Rules: DOL Proposal Meets CAA 2026
Nixon Peabody LLP 
[Guidance Overview] June 11, 2026 "The DOL proposed rule (if finalized) and CAA 2026 encourage transparency and accountability between plan sponsors/fiduciaries and PBMs. With detailed initial and semiannual disclosures, drug-level pricing transparency, and enforceable audit rights, plan sponsors and fiduciaries can: [1] Compare PBM models and evaluate which approach delivers the best value. [2] Identify spread pricing exposure at the individual drug level. [3] Attempt to negotiate transparent pass-through compensation arrangements." MORE >> |
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