American Pharmacists Association (APhA)
EBSARulemakingEBSA-2026-0001

Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure

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Last modified
Jan 30, 2026
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closed 119d ago
American Pharmacists Association (APhA) filings
1

Activity

American Pharmacists Association (APhA) filed 1 comment on this docket between Apr 15, 2026 and Apr 15, 2026. 4 other organizations filed here. The comment window closed 119d ago.

What American Pharmacists Association (APhA) filed (1)

Apr 15, 2026· 1210-AB37 comment 0109 American Pharmacists Association 04152026· EBSA-2026-0001-0468

Dear Assistant Secretary Aronowitz, The American Pharmacists Association (APhA) appreciates the opportunity to provide EBSA and the U.S. Department of Labor (Department) comments on the "Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure," proposed rule. As the Department understands, ERISA §408(b)(2) expressly authorizes disclosure conditions. APhA represents pharmacists, student pharmacists, and pharmacy technicians in all practice settings, including but not limited to community pharmacies, hospitals, long-term care facilities, specialty pharmacies, community health centers, physician offices, ambulatory clinics, managed care organizations, hospice settings, and government facilities. Our members strive to improve medication use, advance patient care, and enhance public health. Full comments are attached.

Abstract

The Department is proposing a regulation that would require providers of pharmacy benefit management services and affiliated providers of brokerage and consulting services to disclose information about their compensation to fiduciaries of self-insured group health plans subject to the Employee Retirement Income Security Act (ERISA). These disclosures are needed so that fiduciaries can assess the reasonableness of the contracts or arrangements with these service providers, including the reasonableness of the service providers' compensation. These disclosure requirements would apply for purposes of ERISA's statutory prohibited transaction exemption for services arrangements. This proposal implements section 12 of President Trump's Executive Order 14273, Lowering Drug Prices by Once Again Putting Americans First, which instructs the Department to propose regulations to improve employer health plan transparency into the direct and indirect compensation received by pharmacy benefit managers. If finalized, this regulation would affect sponsors and other fiduciaries of self-insured group health plans and certain service providers to such plans.

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