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Schaeffer scholars submitted comments to the U.S. Department of Labor supporting a proposed rule to improve visibility into pharmacy benefit manager (PBM) compensation. They recommended several targeted improvements to ensure the final rule delivers meaningful transparency that strengthens fiduciary oversight, promotes competition, and better aligns incentives with the interests of patients and plan sponsors.
Their recommendations include:
- Standardize disclosures for comparability and usability
- Require drug-level and claim-level transparency
- Tighten definitions of compensation to prevent reclassification
- Enhance disclosure of formulary decision drivers
- Require independent third-party audit of PBM disclosures.
Read the full comment letter here.
