Pharmacy benefit managers now have 30 months to prove, claim by claim, exactly how every rebate and price spread was calculated, not just report the totals. The clock starts with transparency provisions buried in the Consolidated Appropriations Act of 2026, signed into law in February, paired with a Department of Labor proposal that would force ERISA plan fiduciaries to judge whether PBM compensation is even reasonable.
The core mandate: PBMs must disclose the gap between what health plans pay them and what they actually reimburse pharmacies, then back it up with gross and net drug costs, rebates, fees, discounts and utilization data, all tied to individual claims. They’ll also have to track wholesale acquisition cost on brand-name drugs, average wholesale price on generics, and total patient out-of-pocket spending per drug.
Lori Daugherty, RxLogic’s CEO, writes in a MedCity News analysis that many legacy PBM platforms were designed for transaction processing rather than claim-level proof. They run on spreadsheets and manual audits that can’t reconstruct pricing logic or trace a rebate from manufacturer to plan, the exact blind spot federal investigators flagged in prior spread pricing and pharmacy steering probes. Congress keeps writing disclosure rules, and PBM infrastructure keeps needing a rebuild to keep up.
The mandate takes effect in 30 months. For PBMs still leaning on spreadsheets, that’s barely enough time to rebuild the plumbing before regulators start asking for receipts.
Sarah Chen