PBM Reforms May Open a New Era for Group Health Plan Sponsors
The federal Consolidated Appropriations Act of 2026 (CAA 2026) and recent regulatory developments could potentially dramatically overhaul reporting and disclosure requirements for pharmacy benefit managers (PBMs) and give new rights to employers sponsoring group health plans generally over the next several years. 00:00 24:53 Quick Hits The Consolidated Appropriations Act of 2026 (CAA 2026) represents the most sweeping federal effort to date to regulate pharmacy benefit managers (PBMs). Most of the changes will not take effect until 2029 (for calendar year plans). At the center of the CAA 2026: full pass-through of rebates and required compensation disclosure by PBMs. The CAA 2026 represents the most sweeping federal legislative effort to regulate the pharmacy benefit management industry to date. Signed into law on February 3, 2026, the CAA 2026 broadly applies to all employer-sponsored group health plans, including both self-funded and fully-insured plans, and creates new mandatory rep...