Insights CenterEventsNews & Press Releases As previously reported, the Department of Labor (DOL) released a proposed rule (Proposed Rule) on January 30, 2026, targeting ERISA disclosure obligations applicable to PBMs. The public comment period closed on April 15, following a 15-day extension, with 564 comments submitted. Below is a summary of some of the key themes we noticed in the comments. Just days after the release of the Proposed Rule, the Consolidated Appropriations Act of 2026 (CAA 2026) was signed into law on February 3, 2026. As discussed previously, the CAA 2026 sets forth a comprehensive statutory framework governing PBM reporting obligations and plan oversight of pharmacy benefit arrangements. Unsurprisingly, the interaction between the Proposed Rule and the CAA 2026 was a prevalent theme in the comments. Notably, these comments did not reflect a single c…

Many of these stakeholders urged the DOL to make targeted, technical refinements to align the Proposed Rule more closely with the statutory requirements. Their concerns centered on the potential compliance burden created by parallel but slightly different regulatory obligations, particularly with respect to definitions, implementation timelines, reporting frequencies, and audit and recordkeeping standards. Amend the Proposed Rule to further strengthen oversight. A separate group of commenters advocated not only for technical alignment, but also for more substantive amendments, contending that neither the Proposed Rule nor the CAA 2026 goes far enough. These commenters called for more robust reforms focused on patients and access to care. Examples include proposals calling for the DOL to amend the rule to fully delink PBM compensation from drug rebates, expand disclosu…