New Landmark Pharmacy Benefit Managers Reform: Increased Transparency, Reporting, Federal Oversight, Enforcement
Barbri Webinar
Date: April 15, 2026
Time: 1:00PM - 2:30PM (EST)
Location: Virtual
Introduction
This CLE webinar will closely examine the landmark legislation in the recently enacted Consolidated Appropriations Act, 2026, with new requirements for pharmacy benefit managers (PBMs) to increase transparency under additional federal oversight. The panel will discuss how counsel may guide covered stakeholders through expansive new obligations and prepare for compliance.
Description
The recently enacted Consolidated Appropriations Act, 2026 (CAA 2026) contains landmark reforms for PBMs. The legislation is a culmination of years of prior legislative and regulatory attempts to increase transparency and oversight of PBMs, drawing from the PBM Reform Act of 2025 and other legislative proposals, and will change longstanding industry practices.
CAA 2026 PBM reforms focus on a number of areas, including increased transparency, standardized reporting, expanded federal oversight, and rebate pass-through. For example, CAA 2026 requires commercial PBMs to remit 100% of all rebates, discounts, fees, and other remuneration received from any applicable entity to the group plan sponsor on a quarterly basis. The law also requires PBMs to provide plans with detailed reports on a semiannual basis (or quarterly upon request) covering a number of categories of information including gross and net prescription drug spending by the plan; manufacturer rebates, fees, and other remuneration received by the PBM in connection with the plan; and a summary document to the health plans to be provided to individual participants and beneficiaries upon request containing information about the plans' prescription drug coverage and spending.
Even though the law's provisions have delayed effective dates and may be subject to future regulatory guidance, counsel should understand how the law will impact covered stakeholders and help them to begin assessments of current contracts and data infrastructure to begin preparing for compliance.
Listen as our expert panel guides healthcare counsel through the expansive new requirements for PBMs and offers best practices for compliance.
