Why Transparent Pricing in Rx Benefits Is a Fiduciary Imperative
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In an era of increasing healthcare scrutiny, employers sponsoring self-funded health plans are facing more pressure than ever to act in the best interests of their plan participants. Central to this fiduciary duty is the way prescription benefits are managed, and for many, the current lack of transparency in pricing is a serious risk.

What Is Fiduciary Responsibility in Health Plans?
Under the Employee Retirement Income Security Act (ERISA), plan sponsors have a legal obligation to act prudently and solely in the interest of plan participants. This means:
- Ensuring the plan pays reasonable fees.
- Monitoring vendors and performance.
- Managing the plan with care and diligence.
These obligations apply not only to overall benefit plan design but also to pharmacy benefit management, an area where transparency is often lacking.
The Problem: Opaque Pharmacy Pricing
Traditional Pharmacy Benefit Managers (PBMs) operate with complex and often hidden pricing models. Employers are typically unaware of:
- How much the PBM pays the pharmacy versus what the plan is charged (spread pricing).
- Whether all manufacturer rebates and incentives are passed through.
- How drugs are selected for the formulary (based on rebates or clinical value?).
This lack of insight makes it nearly impossible for employers to assess whether they’re getting fair value, which puts them at risk of breaching their fiduciary duty.
Real-World Consequences of Poor Oversight

Recent lawsuits, such as the 2023 Wells Fargo case and scrutiny faced by companies like Johnson & Johnson, demonstrate that employers who fail to adequately monitor health plan vendors can be held accountable.
Without pharmacy benefit transparency, it becomes difficult to:
- Justify plan expenses.
- Show that vendors are acting in participants’ best interest.
- Identify and eliminate waste.
Why Transparency Matters Now More Than Ever
Employers don’t need to be pharmacy experts, but they must be able to clearly demonstrate that they’ve evaluated their pharmacy benefit programs and selected cost-effective, transparent partners.

Transparent pricing allows plan sponsors to:
- Track where every dollar is going.
- Evaluate the true cost of medications.
- Align pharmacy benefit design with employee health and financial well-being.
SHARx: A Fiduciary-Friendly Pharmacy Partner
SHARx offers a fully transparent approach to prescription procurement. There are no hidden rebates, no spread pricing, and no vague promises. Instead, SHARx helps employers:
- Source medications at the lowest possible cost.
- Provide better access and lower out-of-pocket costs for employees.
- Reinvest cost reduction into valuable benefits or retention strategies.
By choosing a transparent vendor like SHARx, plan sponsors can confidently meet their fiduciary obligations and unlock meaningful value from one of the most expensive parts of their health plan.
Final Thoughts
Pharmacy benefit transparency isn’t just a best practice—it’s a fiduciary imperative. As legal expectations rise and benefit costs grow, employers must reexamine their partnerships and push for greater clarity in pricing, performance, and value.
Is your current pharmacy partner helping you meet your fiduciary duty? If you’re unsure, it might be time for a transparent alternative. Connect with SHARx to learn more.
