DOL Releases Final Rule on PBM Fee Disclosure
Published October 29, 2026
The Department of Labor’s Employee Benefits Security Administration (EBSA) released a final rule requiring pharmacy benefit managers (PBMs) and their affiliated brokers and consultants to disclose their fees and compensation to fiduciaries of self-insured group health plans.
The PBMs disclosures will allow plan fiduciaries to assess the reasonableness of compensation for the services and to fulfill their duties under ERISA. The final rule allows plan fiduciaries to audit the accuracy of PBM disclosures.
PBM Disclosures
Issued under ERISA’s statutory service provider prohibited transaction exemption, the final rule requires PBMs to disclose the following information:
- Rebates and other payments from drug manufacturers
- Compensation received when the price paid by the plan for a prescription drug exceeds the amount reimbursed to the pharmacy
- Payments recouped from pharmacies in connection with prescription drugs dispensed to plan participants
Service providers
The final rule provides compliance-assistance information for all service providers to employer-sponsored group health plans, which are now required to report fees and compensation to group health plan fiduciaries following the passage of the Consolidated Appropriations Act, 2026.
The final rule is effective January 4, 2027, and applicable to plan years beginning on or after July 1, 2027.