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ARTICLE · 16 FEBRUARY 2026

PBM Reform Cheat Sheet: Chart Comparing The Recent Rules For Group Plans

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Within a one-week period, there were two actions at the federal level to increase pharmacy benefits manager (PBM) transparency. The Consolidated Appropriations Act of 2026 (CAA 2026) and Department of Labor...

United StatesEmployment and HR
Nick Welle
Nick Welle
Hannah R. Demsien
Hannah R. Demsien
Iris Grossman
Iris Grossman
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Key Takeaways:

Within a one-week period, there were two actions at the federal level to increase pharmacy benefits manager (PBM) transparency. The Consolidated Appropriations Act of 2026 (CAA 2026) and Department of Labor (DOL) proposed regulations on PBM compensation disclosures (DOL Proposed Rules) are complementary but differ in significant respects. CAA 2026 is broader in scope (applying to all group health plans, including fully insured arrangements), but has a later effective date and creates distinctions based on employer/plan size. In contrast, the DOL Proposed Rules only cover compensation disclosures and apply only to self-funded ERISA plans but would take effect much sooner and apply uniformly regardless of employer size.

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