DOL Final Rule Will Force PBMs to Divulge Their Revenue Model Details

The U.S. Department of Labor’s Employee Benefits Security Administration (EBSA) on Thursday, Oct. 29, finalized a landmark rule that will force pharmacy benefit managers, brokers and consultants to fully disclose their fees and financial compensation to large employers’ self-insured group health plans.

This regulation will be effective 60 days after its publication in the Federal Register and is applicable to plan years beginning on or after July 1, 2027.

Under the new regulatory framework, titled “Improving Transparency into Pharmacy Benefit Manager Fee Disclosure,” corporate employers will, for the first time, gain full line-item visibility into the structural revenue model of the pharmaceutical supply chain. This bookkeeping trail would include:

Rebates and other payments from drug manufacturers;
Compensation received when the price paid by the plan for a prescription drug exceeds the amount reimbursed to the pharmacy; and,
Payments recouped from pharmacies in connection with prescription drugs dispensed to plan participants.

The final rule targets many of these hidden revenue streams by exposing exactly how much drug manufacturers, commercial pharmacies and secondary supply chain entities pay third-party PBMs. Federal officials noted corporate plan sponsors can leverage this pricing transparency to:

Renegotiate more favorable administrative contracts;
Structure competitive pharmacy networks; and,
Drive down out-of-pocket prescription medication costs for their employees who receive healthcare benefits.

The Department of Labor (DOL) believes the rule will positively impact 90 million American workers and dependents.

U.S. Secretary of Labor Keith Sonderling called the action “a win for every American worker who has ever paid too much at the pharmacy counter” and said this would apply liability to PBMs that “for years … have operated in the shadows, pocketing hidden fees while workers and employers were left in the dark.”

The enforcement initiative forms a central pillar of an ongoing administrative push to restructure healthcare market pricing through open competition. The multi-agency transparency push focuses heavily on removing hidden commercial accounting and backend broker kickbacks that conceal the true marketplace value of prescription therapies.

“More transparency means more competition, and more competition means lower healthcare costs,” said Centers for Medicare and Medicaid Services (CMS) Administrator Dr. Mehmet Oz. “Today’s new rule represents a significant step forward in this administration’s all-of-government effort to take the guesswork out of shopping for healthcare — an effort in which [the DOL], CMS, and numerous other agencies and departments all have important roles to play.”

The framework also works to:

Codify the statutory bipartisan transparency directives passed by Congress under the 2026 Consolidated Appropriations Act; and,
Satisfy a principal requirement of President Donald Trump’s April 15, 2025, executive order (“Lowering Drug Prices by Once Again Putting Americans First”), which tasked federal oversight divisions with standardizing supply chain reporting and increasing accountability across retail prescription markets.

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