PBM Reform 2026: What Recent Legislation Means for the Industry
PBM reform 2026 is reshaping how PBMs and plan sponsors operate, as Congress and federal agencies introduce new compliance requirements and enforcement standards. With multiple reforms moving forward at once, many organizations are asking: what changed, what’s required, and what comes next?
Mintz Health Care Law attorneys analyze PBM reforms enacted under the Consolidated Appropriations Act of 2026 (CAA 2026), along with proposed Department of Labor rules, recent FTC enforcement activity, and federal drug pricing initiatives.
What you’ll learn:
- Key PBM reform 2026 requirements and emerging compliance risks
- How recent agency actions may affect PBM operations and contracting
- What to prioritize as PBM regulation continues to evolve
Authors
Theresa C. Carnegie
Member
Theresa advises clients on all aspects of the pharmaceutical supply chain, including counseling industry stakeholders on a range of business, legal, transactional, and compliance matters. She provides clients with strategic counseling and creative business modeling that considers legal restrictions and regulatory risk in light of innovation and business goals.
Bridgette A. Keller
Member
Bridgette advises health care providers, ACOs, health plans, PBMs, and laboratories on regulatory, fraud and abuse, and business planning matters, applying her experience in health system administration and ethics in health care to her health law practice.
Hassan Shaikh
Associate
Hassan advises a broad range of clients across the health care industry—including health care systems, pharmacies, and private equity firms investing in health care companies—in complex industry transactions and compliance and regulatory matters.