Federal PBM Reform and Employer Plans: What the 2026 Law Changes, and When
The Consolidated Appropriations Act, 2026 requires PBMs to pass through 100% of rebates to ERISA plans, disclose compensation, and report drug-level data. Here is what changes for self-funded employers, the 2028–2029 timeline, what the law does not do, and what to put in PBM contracts now.
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