Insights CenterEventsNews & Press Releases Despite the flurry of reform activity throughout the first quarter of 2026, the pace of new PBM regulation and drug pricing reforms shows no sign of tapering off. Instead, both federal and state legislatures continue to target PBMs and drug pricing practices. The White House seems to be moving forward with efforts to codify President Trump’s MFN drug pricing deals. According to reports, in an effort to gain industry support of the federal legislative efforts to codify the deals, the administration has drafted legislative text and invited a small group of pharmaceutical manufacturers to discuss. This push for codification comes despite bipartisan hesitation in Congress, where several lawmakers have raised questions about the scope, mechanics, and long‑term implications of the MFN agreements. As recently discussed, some members…

In December 2025, federal lawmakers introduced the bipartisan PBM Fiduciary Accountability, Integrity, and Reform (“FAIR”) Act, which would impose fiduciary duties and responsibilities on PBMs. Specifically, the proposed legislation would amend the Employee Retirement Income Security Act (ERISA) to deem PBMs as fiduciaries to ERISA-covered group health plans under law. In addition, a number of states have recently introduced legislation proposing to impose fiduciary obligations on PBMs. These efforts reflect an ongoing policy interest in redefining the role of PBMs within the prescription drug supply chain and holding them to heightened, fiduciary standards in their business and contracting practices. Specifically, states have proposed fiduciary obligations in a range of contexts, typically seeking to establish PBMs as fiduciaries, or held to fiduciary standards, eith…