Insights CenterEventsNews & Press Releases Highlights include federal implementation and oversight activity, state-level reform initiatives, significant court challenges, and emerging trends affecting PBMs, health plans, pharmacies, and related stakeholders. Updates on Trump Administration Initiatives Opioid Cases Against PBMs and the Statute of Limitations Congress Enacts Landmark PBM Reforms in the 2026 Spending Bill. On February 3, 2026, Congress passed – and the President signed – the Consolidated Appropriations Act, 2026 (CAA 2026). The legislation includes a long‑anticipated and far‑reaching package of PBM reforms. These reforms draw from the PBM Reform Act of 2025 and other legislative proposals and will significantly reshape PBM operations across the commercial market and Medicare Part D beginning in 2028–2029. The reforms center on rebate pass‑through, increa…

Stakeholders should begin preparing for material operational and contractual changes well ahead of the effective dates. See our blog post for more information. DOL Proposes New PBM Fee Disclosure Rule. On January 30, 2026, the Department of Labor released a proposed rule that would end long‑running confusion about how ERISA disclosure obligations apply to PBMs under the Consolidated Appropriations Act, 2021, and give fiduciaries of ERISA‑covered self‑insured group health plans significantly expanded visibility into PBM services and compensation. The proposal pairs broad compensation transparency with comprehensive audit rights covering PBMs and their affiliates, agents, and subcontractors, including PBM‑affiliated brokers and consultants. See our blog post for more information.