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 closely examined landmark legislation in the recently enacted Consolidated Appropriations Act, 2026, which introduced new requirements for pharmacy benefit managers (PBMs) to increase transparency under enhanced federal oversight. The panel discussed how counsel could guide covered stakeholders through expansive new obligations and help them prepare for compliance.
Description
The recently enacted Consolidated Appropriations Act, 2026 (CAA 2026), introduced landmark reforms for PBMs. The legislation represented the culmination of years of prior legislative and regulatory efforts to increase transparency and oversight of PBMs, drawing from the PBM Reform Act of 2025 and other legislative proposals, and changed longstanding industry practices.
CAA 2026 PBM reforms focused on several areas, including increased transparency, standardized reporting, expanded federal oversight, and rebate pass-through. For example, CAA 2026 required 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 required PBMs to provide plans with detailed reports on a semiannual basis (or quarterly upon request) covering multiple 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 for health plans to provide to individual participants and beneficiaries upon request, containing information about prescription drug coverage and spending.
Although the law’s provisions had delayed effective dates and were subject to future regulatory guidance, the program emphasized the importance for counsel to understand how the law would impact covered stakeholders and to assist them in beginning assessments of existing contracts and data infrastructure in preparation for compliance.
Attendees heard from an expert panel that guided healthcare counsel through the expansive new requirements for PBMs and shared best practices for compliance.
