2026 Pharmacy Benefit Manager Reform Overview

This document is a guide detailing the significant reforms related to pharmacy benefit managers (PBMs) enacted in early 2026. It outlines three key federal actions that aim to enhance transparency and reduce healthcare costs for employers. The first major action is the 2026 Consolidated Appropriations Act (CAA), which introduces new requirements for PBM contracts, effective January 1, 2029. Employers are advised to review their contracts early to ensure compliance, as non-compliant contracts cannot be renewed. The second action is a proposed rule by the U.S. Department of Labor (DOL) aimed at increasing visibility into PBM compensation for self-insured group health plans. The final action involves a settlement between the Federal Trade Commission (FTC) and Express Scripts, requiring changes to its PBM services. The document also summarizes the implications of these reforms for employers and the necessary reporting requirements for PBMs.