With the Consolidated Appropriations Act of 2026 and a Department of Labor proposal focused on PBM disclosures, employers are seeing more headlines and asking sharper questions about how their pharmacy benefits are structured.
This post explains what changed, what did not, and what it means for your plan.
What changed
1) ERISA amendments under the Consolidated Appropriations Act of 2026
Congress amended ERISA to increase expectations for PBM transparency and oversight in employer-sponsored plans. For plan sponsors, the law focuses on:
- Clearer PBM reporting and transparency into drug pricing and fee arrangements
- Rebate and discount pass-through requirements
- Greater visibility into PBM compensation and affiliated relationships
- Defined audit rights and enforcement mechanisms
Most employer-focused provisions are scheduled to take effect in summer 2028.
2) Department of Labor proposed disclosure rule
The Department of Labor has proposed expanded PBM disclosure requirements for self-funded ERISA plans. The proposal emphasizes:
- Clear disclosure of rebates and spread pricing
- Transparency into PBM compensation structures
- Audit and fiduciary oversight expectations
Final definitions and reporting formats will shape how these requirements work in practice. You may also see increased attention on manufacturer-direct pricing initiatives such as TrumpRx. These programs can offer visibility into brand pricing outside the traditional PBM structure.
A lower advertised brand price does not automatically translate to a lower net cost once generics, rebates, dispensing channel economics, and overall plan impact are considered.
LucyRx evaluates these programs across multiple dimensions, including manufacturer pricing, negotiated net cost, generic availability, and total plan impact, to determine when they are additive and when they are unlikely to outperform existing cost saving strategies.
Why this matters for employers
PBM reform reinforces a basic expectation that employers already have:
- You should be able to understand how prescription dollars move, how your PBM is paid, and how incentives align with your plan and members.
- Plan sponsors, as fiduciaries, are expected to pay attention to these mechanics and benefit from transparency to do their jobs.
What this means for LucyRx
The name Lucy, which comes from Latin meaning “light,” perfectly symbolizes our mission: to shine a clear light on the path forward in pharmacy benefit management. We strive to support our customers by providing clear and transparent information about the pharmacy benefits management services we provide to help people live healthier, better lives.
The bottom line
PBM reform clarifies expectations. It reinforces transparency, disclosure and fiduciary accountability. If you would like to discuss how these developments apply to your specific plan design, formulary strategy, or member population, your LucyRx team is here to help. We will continue to share updates as they develop.
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