DisclosedRx's PBM Contract Received an “Excellent” Score from the Nautilus Health Institute. Here’s What That Means for You

Let’s start with the obvious: PBM contracts can be confusing for anyone but the most highly trained specialists. Some might say this is by design. 

However, a lack of clarity about the commitments in the contract is becoming untenable as sponsors demand better information about what they’re agreeing to with their PBM.

In July, the Nautilus Health Institute changed the game by publishing an independent scoring of PBM contracts. It evaluated 27 standard agreements against 10 fiduciary provisions. The median score was 54 out of 100; nine contracts scored 90 or higher and received an “Excellent” rating.

The DisclosedRx contract was one of those nine. It also received a “Gold” rating for data sovereignty, which measures data ownership, audit rights, rebate and manufacturer revenue, conflicts of interest, and lowest net cost.

For DisclosedRx, the score matters because it independently confirms that the principles behind our business model are reflected in the contract itself.

Fiduciary alignment, full disclosure, meaningful audit rights, and protection from conflicts of interest aren’t simply promises. They’re in the contract.

CAA 2026 is now bringing many of these same issues into sharper focus for the broader PBM market.

 

Who is the Nautilus Health Institute?

Nautilus is a 501(c)(3) nonprofit that publishes procurement tools, contract standards, and independent contract scoring for employer health plans. It grew out of Health Rosetta, which spent roughly a decade documenting what high-performing self-funded plans were doing differently and turning those findings into standards employers could use.

Three parts of the methodology are particularly relevant. Nautilus scores contract language, not the PBM as a company.

It says PBMs do not pay to be scored, remediated, or listed. And each judgment is tied to the specific contract language behind it.

The PBM project publishes the methodology and standard in more detail.

What the PBM contract score measures

Nautilus grades 10 provisions across three areas: fiduciary conduct, financial integrity, and oversight and control. The score is based on the language as written. If a contract is silent on a protection, that silence generally scores poorly because the plan may not have a clear right to enforce later.

These are practical rights, not just technical contract provisions. They determine what the plan can see, verify, retain, and change before claims are paid and money changes hands.

Two provisions have an obvious connection to the money: pass-through pricing determines whether the plan pays what the pharmacy was actually paid.

Rebate definitions determine whether manufacturer dollars reach the plan or are reclassified along the way. That is the issue illustrated by a member paying $1,000 for a $500 medication.

In either case, the problem can exist because the contract allows it. The DisclosedRx model was built around commitments intended to prevent that kind of ambiguity.

 

Why the contract matters more than a good reputation

A PBM may say it does not retain spread, does not steer members to its own pharmacies, or passes through manufacturer revenue. Those statements are useful, but ultimately, they’re toothless unless the contract makes the same commitments.

Companies, leadership, and business pressures change. The contract is what the plan can rely on when the practice changes. That is one reason the Nautilus scoring process matters: the score is tied to the actual language, not to what a PBM says it intends to do.

What CAA 2026 changes for PBM contracts

Congress passed the Consolidated Appropriations Act, 2026, on February 3. Its PBM provisions take effect for plan years beginning on or after August 3, 2028, which means January 1, 2029 for a calendar-year plan.

That may sound far away, but contracts signed or renewed now can still be in place when the new requirements take effect. CAA 2026 adds requirements around PBM compensation and disclosures, making contract language around rebate pass-through, transparency, and auditability increasingly important.

The practical issue is simple: a plan cannot evaluate whether compensation is reasonable if the contract prevents it from measuring what it is paying. An audit provision that restricts the auditor, limits findings, or withholds information may look like an audit right without giving the plan much ability to verify the numbers.

For the legal and regulatory detail, see the full CAA 2026 and Department of Labor materials linked in this article.

What brokers and TPAs should take from this

The same contract questions matter to brokers, consultants, and third-party administrators. A strong procurement process also shows that someone reviewed the PBM contract, compared it with a defined standard, and documented the provisions that needed attention.

For TPAs in particular, data ownership and carve-out rights deserve attention. If the plan does not control its claims data or cannot move a drug category without a penalty, other integration and cost-containment strategies may depend on the PBM’s approval.

 

Three things to check before your next renewal

Start with three clauses: audit rights, data ownership, and termination.

Audit rights: Who can conduct the audit, and what are they allowed to review?

Data ownership: Who owns the claims data, and what happens to it when the relationship ends? Termination: What notice, penalties, or other costs apply if the plan wants to leave?

You should also ask the incumbent PBM for its Nautilus score. The rubric is public and can be applied across contracts. And when you run your next procurement, make the contract standard part of the bidding process rather than waiting until the end to find out which vendors will accept it.

 

Final thoughts

For DisclosedRx, the Excellent score is independent confirmation that the commitments behind the Fully Disclosed PBM model are reflected in the contract.

To see how your agreement compares, request a call. We can walk a benefits team through the 10 provisions and show where its PBM contract stands on each one, whether or not the team is already a client.