CAA 2026: The Industry Is Being Forced to Do What We've Always Done

Congress just passed the most comprehensive PBM reform legislation in history. The Consolidated Appropriations Act of 2026 mandates sweeping changes that will reshape how pharmacy benefit managers operate.

Starting in 2028, federal law will require all PBMs to pass through 100% of rebates to plan sponsors. They'll be restricted to earning only bona fide service fees.

They'll need to provide detailed reporting on drug spend, pricing, and compensation. They'll be held to new standards of disclosure and accountability.

For DisclosedRx, this changes nothing.

We've Been Here All Along

Our contracts have always guaranteed 100% rebate pass-through and 100% pricing pass-through. We've always operated on a single admin fee structure, plus a 25/75 savings split that delivers measurable ROI to our clients. We've always provided complete visibility into pharmacy benefit costs. Not because regulations required it, but because it's the right thing to do.

While other PBMs built their businesses around spread pricing and multiple revenue streams, we built ours around Full Disclosure. We chose to be contractually obligated to act in our clients' best interests from day one. It's not a compliance strategy. It's who we are.

They're Adapting. We're Already There.

Over the next 30 months, traditional PBMs will scramble to restructure their entire business models. They'll rewrite contracts, implement new systems, and figure out how to survive on service fees alone. They're learning how to operate in a way they've actively resisted for years.

Not because they want to. Because they have no other choice.

Meanwhile, DisclosedRx will continue operating exactly as we have since we started. No disruption. No learning curve. No compliance overhaul. Our clients and their members won't experience any changes, because we've been meeting these standards all along.

The Question Plan Sponsors Need to Ask

Your current PBM will spend the next two years preparing for mandated changes. They'll adjust to requirements they've fought against. They'll learn to operate with Full Disclosure because federal law now demands it.

Why would you want to partner with someone who's figuring out how to do what we've been doing all along?

What This Reveals

If 100% rebate pass-through and single-source pricing were good for plan sponsors, PBMs would have adopted them voluntarily. They didn't. They needed Congress to force their hand. That tells you whose interests they've been serving.

CAA 2026 doesn't change our approach. It validates it. Full Disclosure has always been our foundation. The Fiduciary and Fully Disclosed PBM® isn't a response to regulation. It's a promise we've kept in every contract.

Our Business Model Has Always Been to Do the Right Thing

While the industry prepares for compliance, we remain focused on what matters: serving our clients and their members. Controlling specialty drug costs. Ensuring members get their medications without financial burden. Making the complex simple.

We've been operating this way all along. Not because we had to. Because we chose to.

When CAA 2026 takes effect, you'll have a choice: partner with a PBM that's being forced to change, or continue with one that's been doing it right from the start.

We've been ready.