PBM reform is here.

ClearScript remains committed to transparency.

For plan sponsors, recent federal reforms mean PBM decisions should be easier to understand and evaluate year-round. New CAA 2026 reporting requirements, the Department of Labor’s (DOL) proposed PBM fee disclosure rule, and the Federal Trade Commission’s (FTC) settlement with Express Scripts together mark a decisive shift toward greater accountability in pharmacy benefit management. At ClearScript, this momentum aligns with how we’ve always operated: providing straightforward information that explains your pharmacy benefit and helps you understand where your benefit dollars are being spent.

As part of our service commitment, ClearScript is actively monitoring these developments. We will keep clients informed as agency guidance becomes available and requirements take effect. We’ll also share insights to help you understand and prepare for potential changes that may impact your plan.

What is the Consolidated Appropriations Act?

In response to ongoing concerns about rising drug costs and limited visibility into pharmacy benefit practices, Congress originally passed the Consolidated Appropriations Act (CAA) in 2020. The law establishes requirements for healthcare and employee benefit plans, including how pharmacy benefits are administered, disclosed and monitored. The most recent amendments, signed into law on February 3, 2026, represent the most significant PBM reforms to date.

What has changed?

At a high level, the CAA amendments set new standards requiring PBMs to provide plan sponsors with increased visibility into pricing, compensation and rebate activity. These requirements are designed to support informed oversight of prescription drug benefits.

In parallel, the DOL has proposed additional PBM fee and compensation disclosure requirements and the FTC’s landmark settlement with Express Scripts underscores the broader push toward more transparent PBM practices.

What Transparency and Accountability matter?

The CAA 2026 amendments mark an important shift — strengthening plan sponsors’ ability to understand, evaluate, and hold their PBM accountable.

Taken together, these developments reinforce a clear expectation: PBM arrangements should be understandable, auditable, and aligned to true costs and member access. At ClearScript, we believe you should receive plan-level reporting and documentation, along with dedicated account support to help you interpret it.

Semiannual reporting allows plan sponsors to know where their benefit dollars are being spent. Combined with visibility into rebates, pricing methodologies and fees, plan sponsors can see whether they are getting savings and identify the right questions to ask their PBM.

With clear visibility into pharmacy spend and benefit strategy, it becomes easier to evaluate performance, confirm alignment with organizational goals, and identify opportunities for improvement. That clarity strengthens oversight, builds trust, and supports more productive conversations, giving plan sponsors the confidence to adjust their benefits when needed.

Key Dates at a Glance

A Longstanding Commitment

For ClearScript, transparency and accountability are not new initiatives introduced in response to reforms. They are core to how we show up for our clients and how we earn trust. As standards continue to evolve, we remain focused on clear reporting, informed decision‑making, and responsive partnership.

We will be ready for compliance as required under the CAA and any related guidance, recognizing that effective dates and reporting mechanics may evolve as federal agencies finalize rules. In the coming months, we’ll share timing and details for required reporting, as well as any additional compliance updates, so you know what to expect.

Questions? We are here.

If you have questions about how these regulatory changes affect your plan, please reach out to ClearScript.