Found a Better Deal? Your Contract Says No. Why Your PBM Has No Obligation to Optimize. And Penalizes You for Trying. Executive Brief Here’s a sentence from an actual PBM contract: “Any agreement or arrangement entered into by Client, directly or indirectly, will invalidate Client’s ability to obtain Rebates.” The employer found a better deal. The PBM’s response: void all rebates. Most employers assume their PBM is actively looking for the lowest-cost drug option in each situation. That’s...
11 days ago • 5 min read
The Rebate Trap Your Money. Their Leverage. Executive Brief Here's a scenario playing out in conference rooms across the country right now. An employer discovers their PBM is underperforming. Costs are rising. Transparency is lacking. The fiduciary committee agrees: it's time to explore other options. Then someone asks the obvious question: "What happens to our rebates if we leave?" The answer stops the conversation. The contract says rebates are forfeited upon early termination. Money the...
18 days ago • 7 min read
The 2029 Myth CAA 2026 Compliance Starts Now, Not in Three Years Executive Brief "It Doesn't Kick In Until 2029." That's the most misconstrued deadline in employer benefits right now. Yes, the CAA 2026's rebate pass-through and reporting requirements take effect for plan years beginning on or after August 3, 2028 (January 1, 2029 for calendar-year plans). But that headline obscures three realities that make 2026 the year to act: First, the "covered service provider" clarification has no...
25 days ago • 5 min read
The Audit Test The Simplest Way to Know If Your PBM Is Transparent Executive Brief Here's a question telling you everything you need to know about your PBM relationship: Can you audit them without restrictions? If the answer requires a paragraph of qualifications, they're not transparent. Those qualifications exist to protect their revenue, not your participants. This week, I'm walking through the specific audit restrictions we've found in contracts. Some are absurd. Some are infuriating. All...
about 1 month ago • 4 min read
The Old Dog’s New Trick Why a well-built AI prompt does something no form letter ever could Executive Brief Last week I gave you a PDF. A well-designed one, with clear instructions and a sample letter dozens of you downloaded. I felt good about it. But then I got one question: “You said we should customize and personalize the letter. How do we actually do that?” So I spent a few days thinking, tinkering, and building something different. Turns out the old dog needed to learn some new tricks....
about 1 month ago • 5 min read
We Wrote the DOL Comment Letter So You Don't Have To Just Add Your Name The DOL proposed rule on PBM compensation disclosure is the first time regulators have asked employers directly: what do you need to see from your pharmacy benefit vendors? Comments close March 31. Most employers have never submitted a public comment. So we built the tools to make it simple. Two free resources, ready now: DOL Sample Comment Letter A sample employer comment letter you can personalize and submit to the DOL...
about 1 month ago • 1 min read
Show Me the Math What Your PBM Isn’t Showing You What would you do if you were told your PBM earned a 9% margin and researchers found the real number could be closer to 87%? That’s not a hypothetical. A USC Schaeffer Center white paper published in January showed PBM profit margins on the same drug can range from 9% to 87% depending on how the PBM accounts for pass-through payments and internal transfers within its parent company. The DOL just proposed a rule to cut through that fog and other...
about 2 months ago • 7 min read
The Law Changed. The Game Hasn’t. Cigna’s CEO Told Wall Street PBM Reform Won’t Affect Profits Executive Brief On February 3, 2026, President Trump signed the Consolidated Appropriations Act (CAA) of 2026 into law. The legislation includes the most comprehensive federal PBM reform package ever enacted. 100% rebate pass-through. Spread pricing prohibitions. Expanded ERISA 408(b)(2) disclosure requirements. Semi-annual reporting. Enforcement penalties of $10,000 per day. This is a generational...
about 2 months ago • 10 min read
The Question You Didn't Ask What The Voluntary Benefits Lawsuits Reveal Executive Brief The Schlichter voluntary benefits lawsuits filed in December expose a two-part failure most employers share: fiduciaries skipped compensation disclosure requests, and when disclosure existed, they accepted the amounts without evaluating reasonableness. That's the allegation against United Airlines, Labcorp, Community Health Systems, and Allied Universal. Major consultancies are named as co-defendants:...
about 2 months ago • 5 min read