By Joe Boyle, President of ClearFile
As PBM compensation disclosure requirements continue to take shape through the Consolidated Appropriations Act (CAA) of 2026 and proposed Department of Labor rulemaking, many PBMs are waiting for final details before taking action.
That instinct is understandable, but it’s the wrong approach. You don’t need final rules to see where disclosure requirements are likely to create pressure. In many cases, the underlying issues are already visible, and now is the time to assess whether that information can be produced consistently, traced back to source data, and applied the same way across plans and reporting periods.
What PBMs Should Be Pressure Testing for New Disclosure Requirements
PBM readiness is often looked at through the lens of reporting capability: can we pull data, assemble a report, and meet the requirement?
But as expectations evolve, what matters is not just whether a number can be generated—it’s whether that number can be produced reliably, supported by underlying data, and repeated without significant variation from one reporting cycle to the next.
Even without final requirements in place, there are several areas where PBMs can start testing whether their current structure is equipped for more detailed and standardized disclosure.
Plan-Level PBM Compensation Visibility
Many emerging requirements point toward more detailed, plan-level views of compensation. The question is whether that information can be produced consistently across different plans—not just in aggregate, and not just as a one-time exercise.
For organizations that have historically operated with more centralized or summary-level reporting, this will be an early pressure point.
PBM Compensation Definition Alignment Across Teams
Compensation reporting depends on how key terms are defined: revenue, rebates, spread, administrative fees, and retained versus passed-through amounts.
But those definitions are not always applied the same way across finance, operations and compliance teams. If the same metric produces different answers depending on who is asked, that misalignment is likely to surface quickly under more structured disclosure.
Data Traceability in PBM Compensation Data
As expectations increase, so does the need to trace reported figures back to underlying data.
But compensation data is often spread across systems, and assembling a complete view can require combining multiple data sources, assumptions and adjustments. If producing a new number requires reconstructing it each time, that creates real risk around accuracy, documentation and reviewability.
Operational Ownership of PBM Disclosure Readiness
Disclosure readiness isn’t just about data. It also depends on whether the organization has clear ownership, aligned teams, and enough capacity to produce, validate, and maintain disclosures over time.
For many PBMs, that work will span finance, compliance, operations, legal, IT, and external partners. If responsibilities are fragmented or the work is simply added onto already overwhelmed teams, that can become a real pressure point as disclosure expectations become more structured.
Repeatability of PBM Reporting
Another key question is whether reporting can be reproduced consistently. If the same report was generated twice, would it produce the same result? Or does the output depend on manual processes, one-off decisions or interpretation that varies from one cycle to the next?
Repeatability is what makes reporting usable over time. It’s what turns a one-time output into a process that can be relied on across plans and reporting periods.
PBM Compensation Transparency and Explainability
Finally, there’s a more foundational test that comes with increasing disclosure requirements: can the PBM clearly explain how its compensation model works? Not just what the numbers are, but how they are constructed, why certain amounts are retained or passed through, and how those decisions are applied across plans.
As compensation visibility increases, the ability to explain the model becomes just as important as reporting on it.
How PBMs Should Prepare Before Disclosure Requirements Are Final
The details of disclosure requirements are continuing to evolve, but waiting for complete clarity before evaluating readiness can delay the work that matters most.
The goal at this stage is not to build a final reporting package, but to understand where the underlying gaps are likely to surface—whether in data structure, definition alignment, reporting processes or overall confidence in the output.
The PBMs that start this work now will be in a stronger position when requirements are finalized. And more importantly, they’ll be better prepared to respond with consistency and confidence as compensation visibility becomes a more central part of PBM oversight.
