Brown & Brown urges employers to review PBM contracts for new disclosure requirements
BRO•Brown & Brown urged employers to update pharmacy benefit manager contracts for enhanced compensation disclosures covering plan years beginning on or after July 1, 2027. The Labor Department’s final rule applies to certain self-funded ERISA plans with at least 100 participants or employers averaging at least 100 employees.
1. Disclosure deadlines
Brown & Brown urged employers to update pharmacy benefit manager (PBM) contracts for enhanced compensation disclosures under a Labor Department final rule. The rule covers self-funded ERISA plans with at least 100 participants or sponsors averaging at least 100 employees, for plan years beginning on or after July 1, 2027.
2. Reporting and oversight
PBMs must provide initial compensation disclosures at least 90 days before contracts begin, renew or extend. Ongoing disclosures are due within 30 days of each six-month period, though plans can request quarterly reporting. Plan fiduciaries must monitor compliance, seek corrections for deficient disclosures and report uncorrected failures to the Labor Department.
