FAQ: How DOL’s PBM Disclosure Rule Reaches Drugmaker Contracts

The U.S. Department of Labor (DOL) has finalized a rule under the Employee Retirement Income Security Act (ERISA) requiring providers of pharmacy benefit management services to disclose their direct and indirect compensation, along with formulary placement incentives, to fiduciaries of large self-insured employer health plans. The requirements apply to plan years beginning on or after July 1, 2027.¹ Although the obligations fall on PBMs, the disclosures extend to rebates, price protection payments and formulary arrangements negotiated with manufacturers.¹ Below are answers to the key questions about the rule.