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ARTICLE · 05 NOVEMBER 2026

From Proposal To Final Rule: DOL’s Long-Awaited Final PBM Fee Disclosure Rule Includes Significant Changes And Clarifications

Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.
Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.
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Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.

Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.

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The Department of Labor has issued a final rule requiring pharmacy benefit managers to disclose direct and indirect compensation to large self-insured group health plans, establishing new transparency requirements and audit rights. Expected to reduce prescription drug costs by $22 billion over the next decade, these regulations fundamentally reshape how PBMs report manufacturer payments, spread compensation, and other revenue streams to plan fiduciaries.

United StatesEmployment and HR
Theresa Carnegie
Theresa Carnegie
Hassan Shaikh
Hassan Shaikh
Traci Vitek
Traci Vitek
Grace Callander
Grace Callander
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On October 29, 2026, the Department of Labor (DOL) announced the pharmacy benefit manager fee disclosure final rule (the Final Rule), which establishes compensation disclosure and audit requirements for pharmacy benefit managers (PBMs) and affiliate brokers and consultants. DOL promulgated the Final Rule transparency requirements in response to the April 15, 2025 Executive Order 14273, Lowering Drug Prices by Once Again Putting Americans First, which calls on DOL to impose requirements to increase employer health plan transparency into the direct and indirect compensation received by PBMs. DOL expects the Final Rule to lower prescription drug costs for health plans and participants by as much as $22 billion over the next 10 years.

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