Pharmacy benefit oversight is entering a new phase.
Congress and federal regulators are advancing new PBM transparency compliance requirements that increase reporting obligations, expand fiduciary accountability, and elevate oversight expectations for employer-sponsored health plans.
For employers, brokers, and TPAs, this isn’t just regulatory noise. It represents a structural shift in how pharmacy benefits must be monitored, documented, and defended.
At BRMS, we believe transparency isn’t just about access to data. It’s about the ability to validate it, interpret it, and act on it. That requires the right knowledge and strategic partnerships.
What Is Changing in PBM Transparency?
Federal proposals aim to increase visibility into how pharmacy benefit managers operate and how compensation flows within employer-sponsored plans.
At a high level, new requirements would:
- Require PBMs to provide more detailed prescription drug cost and performance reporting to plan fiduciaries
- Expand disclosure of PBM compensation, including rebates, incentives, and financial arrangements
- Require rebates and negotiated discounts to be passed through to plan fiduciaries
- Broaden the list of service providers that fiduciaries must monitor under ERISA
These efforts signal a clear direction of greater transparency, stronger accountability, and defensible oversight in pharmacy benefits.
The full legislative proposals can be reviewed here:
- https://www.congress.gov/119/bills/hr7148/BILLS-119hr7148ih.pdf
- https://public-inspection.federalregister.gov/2026-01907.pdf
Why Is PBM Transparency Compliance a Fiduciary Responsibility?
Under ERISA, plan sponsors have a duty to act prudently and solely in the interest of plan participants. As pharmacy costs continue to represent a growing share of total healthcare spend, PBM arrangements can no longer operate in a “black box.”
Increased disclosure requirements mean employers will receive more data from PBMs, but more data alone does not equal better oversight.
Employers must now be prepared to:
- Evaluate rebate pass-through structures
- Understand spread pricing and compensation models
- Audit PBM contracts and financial arrangements
- Demonstrate active monitoring of pharmacy vendors
Transparency is quickly moving from a best practice to a baseline expectation.
The Hidden Risk: Receiving Data Without Interpreting It
As reporting and audit expectations increase, the ability to validate and interpret PBM data becomes just as important as receiving it. This is where many organizations face risk.
Raw claims files, rebate summaries, and financial disclosures can be complex and highly technical. Without expertise in contract language, performance guarantees, and rebate mechanics, plan sponsors may struggle to determine:
- Whether contractual terms are being honored
- Whether rebates are fully passed through
- Whether pricing aligns with market benchmarks
Compliance requires more than compliance documentation. It requires insight.
Why Partnership Matters: BRMS + Navion
At BRMS, we focus on delivering transparency through advanced plan analytics and plan performance visibility. But when it comes to independent PBM evaluation and contract oversight, partnering with subject matter experts strengthens fiduciary protection.
That’s why we value our partnership with Navion. They help us work through new and emerging changes through:
- Independent PBM evaluation
- Contract oversight
- Ongoing performance monitoring
- Audit validation
As PBM transparency compliance standards evolve, Navion is closely monitoring regulatory developments and keeping partners informed as details unfold. Together, we can help ensure employers understand, validate, and use it strategically.
Turning Compliance into Competitive Advantage
The regulatory environment is clear: greater scrutiny is coming. But forward-thinking employers see this as an opportunity. Transparency is no longer reactive. It’s strategic.
And working with partners who stay ahead of evolving healthcare, benefits, and economic changes is essential to protecting both plan performance and fiduciary integrity.
Looking Ahead
PBM transparency compliance is not a one-time adjustment. It’s an ongoing discipline.
As healthcare economics shift and federal oversight expands, employers must move beyond passive vendor relationships toward active, documented oversight supported by analytics and independent expertise.
At BRMS, we’re committed to helping our trusted and valued clients navigate this complexity with clarity, confidence, and defensible strategy.
Because in today’s environment, transparency is foundational – not optional.
Connect with one of our experts today to learn more!