Disclosure Won. Now What?

  • 4 Min read

  • September 1, 2026

Susan Thomas, RN, MBA

Susan Thomas, RN, MBA

Chief Commercial Officer
Best Practices
Doctors chart

Disclosure won the argument. 

Employers expect to understand where their pharmacy dollars go. Consultants want clearer answers about rebates, fees, and financial arrangements. Policymakers are pushing for stronger disclosure and audit rights. 

That is real progress. 

It is also where the hard work begins. 

Once a plan sponsor can see more of the pharmacy benefit, what can it do differently? 

Because disclosure is information. 

Employers still need results. 

The market is raising the standard

The Department of Labor’s PBM fee-disclosure rule is currently in proposed form. If finalized as proposed, it would require PBMs serving employer-sponsored self-insured ERISA plans to provide plan fiduciaries with detailed information about direct and indirect compensation. It also would require PBMs to allow plan fiduciaries to audit those disclosures for accuracy. ¹  

The Consolidated Appropriations Act, 2026 also amended ERISA to add provisions related to pharmacy benefit management services. The Department extended the rule’s comment period to allow stakeholders to address how the rulemaking should work alongside those statutory changes. ¹ 

Federal requirements are evolving. What is already clear is that plan sponsors are being asked to understand more about the economics and operation of their pharmacy benefit. 

The market is moving in the same direction. 

Business Group on Health’s new 2027 Employer Healthcare Strategy Survey shows how quickly that expectation is turning into action. Seventy-one percent of respondents said they are using the RFP process to secure lower pricing, 58% are eliminating vendors that underperform, and 52% are adding programs in areas of high cost. ² 

Pharmacy is part of that rethink. Employers reported exploring newer PBM models, formularies that prioritize lowest net cost or clinical effectiveness, and site-of-care strategies. ² 

Employers want a clearer view into the economics. Increasingly, they also want the ability to act on what they learn and hold their partners accountable for the result. 

Visibility is the beginning

A PBM can provide a clearer view into its economics and still leave the employer with rapidly rising specialty spending. 

A contract can pass through rebates while members struggle to begin clinically appropriate therapy. 

A reporting package can show detailed data without giving the plan enough flexibility to respond to what the information shows. 

That distinction matters because pharmacy costs are not becoming easier to manage. Business Group on Health reports that pharmacy now represents 25% of employers’ total healthcare spend and estimates employer drug costs will rise 12% in 2026. ²  

Seeing the problem matters. Understanding the driver matters too. So does the ability to change course. 

A useful pharmacy strategy gives the plan sponsor answers to questions such as: 

  • Which therapies and populations are driving cost?  
  • What is the final net cost after rebates, fees, and other payments?  
  • Why was a particular formulary or pharmacy channel selected?  
  • Where are members encountering avoidable barriers?  
  • Did an intervention produce a measurable result?  

Better visibility makes those answers easier to find. 

The National Alliance’s 2026 Pulse of the Purchaser survey reinforces that point. Employers with complete medical claim-level access reported using an average of 11.9 high-value purchasing strategies, compared with 7.9 among employers with limited or no complete access.3 

Data access alone does not guarantee a better result. But it gives employers more ability to identify a problem, evaluate the options and act. 

That is why visibility is only the beginning. 

GLP-1s show the difference

GLP-1 decisions extend far beyond the price of the medication. 

Plan sponsors are already changing course. Business Group on Health reports that GLP-1 coverage for obesity among respondents fell from 72% in 2025 to 60% in 2026.² The decision is increasingly about more than coverage. Plans are weighing clinical eligibility, indications, member affordability, ongoing support, and long-term financial sustainability. 

Clear economics helps an employer understand part of the decision. It does not determine who should receive coverage, what support members need, or whether the strategy worked. 

Those decisions require good data, clinical judgment, benefit flexibility, and measurable results. 

The same is true for specialty drugs, biosimilars, and gene and cell therapies. These treatments do not fit neatly into a benefit model built mainly to process claims and negotiate discounts. 

Employers need to see the cost. 

They also need a strategy for managing what sits behind it. 

Control is the next test

Financial visibility becomes more valuable when the employer can act on what it learns. 

Can the plan adjust the formulary when the evidence supports a different option? 

Can it evaluate another pharmacy or specialty channel? 

Can it change a clinical program that is not producing results? 

Can it identify a cost driver before it becomes a renewal surprise? 

Can it understand what a pharmacy decision means for the member? 

The answers depend partly on the contract. They also depend on the quality of the data, the flexibility of the operating model, and whether the PBM gives the client meaningful control. 

A report can show what happened. 

A strong pharmacy-benefit model helps the employer decide what happens next.

Proof should be the next standard

For years, PBMs competed on discounts and rebate guarantees. 

The push for disclosure challenged the industry to show more of the economics behind those numbers. 

The next stage requires something harder: evidence that the benefit produced a better result. 

That means being precise about the difference between activity and outcome. 

A program was launched. Did it reach the intended population? 

A lower-cost therapy was identified. Was it adopted? 

A member received support. Was the barrier resolved? 

Savings were projected. Were they realized? 

A model was described as aligned. Did the employer verify the complete financial relationship? 

These distinctions are not academic. 

They determine whether the employer is looking at a capability, a promise, or a result. 

Employers do not have to accept a claim of value simply because the economics are easier to see. 

They should be able to verify what changed.

What comes after disclosure

Clear economics remains a basic requirement of every pharmacy-benefit relationship. 

It is not the finish line. 

The more useful standard is whether better visibility gives plan sponsors the control, intelligence, and accountability needed to manage prescription care more effectively. 

Employers should ask their PBMs what they will disclose. 

Then they should ask: 

What can we change? 

What can we verify? 

How will we know whether it worked? 

Disclosure opened the door. Accountability has to come next. 

¹ U.S. Department of Labor. “Fact Sheet: Proposed Pharmacy Benefit Manager Fee Disclosure Rule,” January 2026; and “U.S. Department of Labor Extends Comment Period for Pharmacy Benefit Manager Fee Disclosure Proposed Rule,” February 27, 2026.
https://www.dol.gov/index.php/agencies/ebsa/about-ebsa/our-activities/resource-center/fact-sheets/proposed-pharmacy-benefit-manager-fee-disclosure-rule 

https://www.dol.gov/newsroom/releases/ebsa/ebsa20260227  

² Business Group on Health. “Cost Volatility Forces Employers To Reassess Healthcare Strategy, Business Group on Health Survey Reveals.” August 25, 2026. https://www.businessgrouphealth.org/newsroom/news-and-press-releases/press-releases/2027-employer-healthcare-strategy-survey  

3 National Alliance of Healthcare Purchaser Coalitions. “Pulse of the Purchaser 2026 Survey Results,” August 11, 2026.
https://www.nationalalliancehealth.org/resources/pulse-of-the-purchaser-2026-survey-results/ 

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