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ARTICLE · 04 FEBRUARY 2026

DOL Proposes Sweeping New Disclosure Rules For Pharmacy Benefit Managers

Foley & Lardner LLP
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On January 30, 2026, the DOL's Employee Benefits Security Administration published proposed regulations (408(b) rules) that would significantly increase transparency requirements for pharmacy benefit managers and ...

United StatesEmployment and HR
Nick Welle
Nick Welle
Hannah R. Demsien
Hannah R. Demsien
Iris Grossman
Iris Grossman
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Background

On January 30, 2026, the Department of Labor's (DOL) Employee Benefits Security Administration (EBSA) published proposed regulations (408(b) rules) that would significantly increase transparency requirements for pharmacy benefit managers (PBMs) and related service providers serving self-funded ERISA group health plans. The proposed regulations would only apply to ERISA plans, not governmental or church plans, and for now are limited in scope to self-funded plans, though the DOL has left space in the proposed regulations to expand to fully insured plans in the future. If finalized, these rules would represent a new expanded federal regulatory framework governing PBM disclosures.

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