PBM Reform Signals the Future — But Employers and Brokers Don’t Have to Wait

The enactment of the Consolidated Appropriations Act (CAA) of 2026 marks a significant step toward greater transparency and accountability in the pharmacy benefit management (PBM) industry. 

For employers, brokers, HR leaders, and executive teams that have struggled to understand the true drivers behind rising pharmacy spend, the legislation sends a clear signal: greater transparency is becoming the standard the industry is expected to meet. 

But there is an important distinction between where regulation is headed and what employers can do today. 

Many of the CAA’s key PBM transparency requirements for employer-sponsored health plans will not apply until plan years beginning 30 months after enactment — meaning August 2028 or later. 

Employers and benefit advisors do not have to wait until then. 

Why wait for regulation to mandate what can already be implemented strategically today? 

Reform Often Confirms What the Market Already Knows

Federal action rarely happens overnight. It typically follows years of scrutiny, investigation, and growing concern about systemic practices. 

The Federal Trade Commission (FTC) has continued to examine the role of PBMs and the financial incentives throughout the prescription drug supply chain. Its 2024 interim report highlighted concerns surrounding the industry’s concentration, vertical integration, rebate arrangements, and incentives that can influence drug pricing and utilization. 

The FTC followed that report with a second interim report in January 2025 examining specialty generic drugs and the markups associated with PBMs and their affiliated pharmacies. 

Together, these developments reinforce a broader industry concern: the pharmacy supply chain has become increasingly complex, concentrated, and difficult for plan sponsors to evaluate. 

The CAA is therefore not an isolated development. It is part of a broader regulatory and market movement toward greater visibility into PBM compensation, contracting, and financial arrangements. 

The industry is moving toward transparency because the status quo is increasingly difficult to justify. 

What the CAA Signals Beyond the Policy Language

The CAA includes provisions addressing PBM compensation, disclosure, contracting, rebate and remuneration arrangements, and access to information for plan sponsors. 

While the details are technical, the broader strategic implications are straightforward. 

The future pharmacy benefits environment is increasingly likely to demand: 

• Greater financial clarity 
• More meaningful access to PBM information 
• Stronger alignment between PBM compensation and plan outcomes 
• Greater accountability throughout the pharmacy supply chain 
• More informed purchasing and contracting decisions 

However, legislation alone does not guarantee immediate behavioral change. 

Important questions remain: 

• How consistently will new requirements be implemented and enforced? 
• How will PBMs adapt their contracting and revenue models? 
• Will new forms of compensation emerge as existing arrangements face greater scrutiny? 
• How quickly will employers see a measurable impact on pharmacy spend? 
• What additional regulatory or legislative changes will follow? 

These questions matter because regulatory change takes time. And for employers, time has a cost. 

The Hidden Cost of Waiting

For employers and benefit advisors, waiting until regulatory deadlines arrive can mean several more renewal cycles under the same PBM structure.

Every renewal cycle can represent an opportunity to improve financial transparency, eliminate unnecessary spend, strengthen contracting terms, and gain greater control over pharmacy strategy.

Organizations that prioritize transparency today can begin to:

• Strengthen negotiating leverage 
• Improve budget predictability 
• Increase visibility into PBM economics 
• Reduce exposure to opaque or misaligned revenue arrangements 
• Strengthen fiduciary oversight 
• Build a more defensible benefits strategy 

The question is no longer whether transparency is coming. The question is how long employers should wait to demand it.

The Regulatory Direction Is Clear — and It Is Continuing to Evolve

The CAA is not the only indication that PBM oversight is changing.

In January 2026, the U.S. Department of Labor proposed additional ERISA-related requirements addressing PBM compensation and disclosure. The proposal would increase transparency around rebates and other forms of compensation and strengthen plan fiduciaries’ ability to obtain information about PBM arrangements.

While proposed rules are not the same as final requirements, their direction is significant.

Federal agencies, lawmakers, and regulators are increasingly focused on the same fundamental issue: Plan sponsors need meaningful visibility into the financial relationships that influence their pharmacy benefits.

For employers, that means waiting for every regulatory requirement to take effect may not be the most strategic approach.

SHARx: Aligned With Where the Market Is Going 

SHARx has long believed that employers should not have to wait for regulation to establish basic principles of transparency. We partner exclusively with transparent, pass-through PBMs and have built our model around financial alignment and visibility. 

This approach was not created in response to the CAA. It reflects a longstanding belief that what most impacts employers and their members should never be obscured. 

That means SHARx clients can operate within a pharmacy benefits model designed around principles that increasingly align with the direction of federal reform: 

• Transparent, pass-through financial arrangements 
• Greater visibility into pharmacy economics 
• Alignment between incentives and plan outcomes 
• A focus on eliminating unnecessary spend rather than obscuring it 
• Greater control for employers and benefit advisors 

As policymakers work toward establishing a stronger transparency standard, SHARx is already operating with those principles at the center of its strategy. 

Progress Is Good. Leadership Happens Ahead of Mandates. 

The CAA represents meaningful progress for the pharmacy benefits industry. But regulation typically establishes a floor, not a ceiling. 

Sophisticated employers and brokers do not need to wait until August 2028 to begin asking harder questions about their PBM relationships. They can start now. 

They can ask: 

• What are we paying our PBM? 
• Where does the money go? 
• What incentives are built into our current arrangement? 
• Are those incentives aligned with the interests of our plan and members? 
• And what would change if transparency were treated as a requirement today rather than a regulatory deadline tomorrow? 

These questions can lead to better decisions long before a new compliance date arrives. 

The Strategic Takeaway

PBM reform is no longer a theoretical conversation. 

The CAA of 2026, ongoing FTC scrutiny, and continued federal attention to PBM compensation and disclosure all point toward a pharmacy benefits environment where transparency, accountability, and financial alignment matter more than ever. 

For many employer-sponsored health plans, significant new federal requirements will not take effect until August 2028 or later. But employers do not have to wait until then to act. The organizations that move now can begin aligning their pharmacy strategy with where the market is going — rather than waiting for regulation to tell them where it must go. 

When employers and brokers work with SHARx, they can partner with a pharmacy benefits strategy built around transparent, pass-through PBM relationships and financial alignment. 

Reform may define where the industry is headed. SHARx helps employers get there sooner.