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On January 30, 2026, the Department of Labor (DOL) published proposed regulations that would require pharmacy benefit managers (PBMs) to disclose direct and indirect compensation that PBMs (and their affiliates, agents, and subcontractors) receive in connection with providing pharmacy benefit management services (or advice, recommendations, and referrals regarding such services) to self-insured group health plans. If an employer has engaged a third-party administrator to provide services, including pharmacy benefit management services, for its self-insured group health plan, the third-party administrator is responsible for obtaining the required information from the PBM and disclosing it to the employer.
The DOL proposal would not apply the disclosure obligations with respect to governmental plans, small employer health reimbursement arrangements, or fully insured group health plans, although the DOL may revisit its application to fully insured plans in future rulemaking.
