The PBM Disclosure Act clarifies existing transparency requirements for brokers and consultants who work with employer-sponsored health plans and receive payments from pharmacy benefit managers (PBMs) or related service providers. Currently, these intermediaries must disclose compensation they receive, but the bill explicitly adds pharmacy benefit management services to the list of services requiring such disclosure, ensuring that both direct payments and indirect compensation arrangements are transparently reported. The Department of Labor has 180 days after the bill becomes law to issue detailed regulations explaining these disclosure requirements, which will take effect for health plans six months after those regulations are finalized. The legislation affects brokers, consultants, PBMs, and third-party administrators involved with employer health plans, as well as the employers and workers who depend on these plans. Congress intends this to be a clarification of rules already in place rather than a new requirement, relating back to transparency provisions that took effect under the No Surprises Act in 2022.
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