PBM Procurement Without the Pain

PBM Procurement Without the Pain

A New Open Source Tool to Cut Through Contracts, Conflicts, and Compliance Risks

Executive Brief

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The biggest ERISA class-action lawsuits have one thing in common: PBM mismanagement—often the result of lax compliance leading to poor procurement.

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Employer fiduciaries have a rare win-win opportunity: start with pharmacy benefits to take litigation risk off the table and deliver immediate savings.

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But traditional PBM procurement is a slog—months of manual prep work, days spent sorting marketing claims from reality, uneven evaluation across reviewers, and wrestling with contract terms that never favor the plan sponsor.

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The result? A process that won’t stand up in an audit—or a courtroom.

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That’s about to change.
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I recently joined Nautilus, the not-for-profit arm of Health Rosetta, as a Board Adviser and the leader of their open source PBM Project. We will soon be launching two game-changers:

• PBM Field Guide – Everything you need to know about PBMs and fiduciary procurement best practices
• PBM Configurator – The tool that puts it into practice, streamlining every step from RFI to RFP into a fast and effective process

Why Fiduciaries Should Start Here

Pharmacy benefits are the perfect starting point because:

• Savings are immediate and substantial
• Health outcome improvements are measurable and repeatable
• Risk exposure can be reduced quickly with the right contract terms

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Yet the barriers are real. Employers often:

• Rely on conflicted advisors who aren’t incentivized by savings or transparent contracts
• Lack a systematic way to compare vendors on compliance, clinical rigor, and costs
• Struggle to sort marketing claims from reality
• Use evaluation processes that don’t meet fiduciary criteria—and can’t be defended in an audit or court

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As Dave Chase likes to say:

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The Nautilus Advantage

The Nautilus PBM Field Guide will soon be open-sourced—a comprehensive reference for everything you need to know about PBMs and fiduciary-aligned procurement.

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The PBM Configurator takes the next step: turning knowledge into action. Designed by PBM experts and ERISA attorneys and purpose-built for employers and advisers.

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The PBM Configurator delivers:

• RFI and RFP templates with model contract language
• Question analytics to ensure the right mix of questions
• Spreadsheet templates with instructions for vendor responses
• Heat-mapped vendor comparisons with raw vs. weighted views
• Audit-ready documentation including scorecards and rankings

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285+ Expert-Curated Questions Across 11 Topic Areas

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Question Analytics Dashboard

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Vendor Comparison Dashboard With Heat Map

Bottom line: Slash RFx development time from months to days—while improving decision quality and defensibility.

Case in Point: Running a Two-Track Strategy

A plan sponsor can simultaneously:

1. Run a Compliance RFI with the incumbent PBM to document contract misalignment and drive corrections. Or document the justification to go out for a competitive bid if the PBM response is hesitant, evasive, or outright non-compliant.
2. Run a Market Test RFI with alternative PBMs to gauge market capabilities, establish benchmarks, and generate a shortlist for a subsequent RFP.

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Result: You keep the process defensible, preserve negotiation leverage, and make data-backed decisions—fast.

5 Fiduciary Risks the PBM Configurator Eliminates

• Conflicted advisors who aren’t incentivized by savings or transparency
• Weeks (or months) lost to manual drafting and evaluation
• Vendor proposals that can’t be objectively scored
• Documentation gaps that won’t stand up in an audit—or court
• Letting vendors control your contract and your outcomes

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If you’re running PBM procurement the old way, these risks are already working against you.

Your Opportunity to Go First

We’re looking for early users—both advisors and employers—who want to cut through the noise and make PBM procurement fast, defensible, and conflict-free.

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Let’s connect at RosettaFest for a conversation and a demo.
Not going to RosettaFest? Let’s schedule a discussion and brief demo in early September.

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📩 Reply to this email or message me on LinkedIn to secure an early spot.

The PBM Field Guide Is Coming

The tools to operationalize PBM reform are on the way.

This summer, Nautilus is launching the PBM Field Guide at RosettaFest 2025 in Denver—a practical roadmap to apply the best of state reform, align with fiduciary principles, and take back control of your pharmacy benefits.

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The guide is structured around the Six Pillars of Fiduciary-Aligned PBMs:

• Clinical stewardship
• Full financial transparency
• Unconflicted procurement
• Data ownership & protection
• Local access & provider fairness
• Attestation & oversight

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Advisers and employers will be able to:

• Make confident, compliant decisions in the best interest of plan participants
• Use open-source RFP language, contract terms, and transparent pricing standards
• Avoid hidden fees, audit obstacles, and rebate distortions
• Build oversight systems that keep vendors honest—and participants protected

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Join the Brightest Minds, Leaders, and Change Makers.

Tired of the dark? Join us at RosettaFest 2025—and help build the future of pharmacy benefits. You’ll never look at PBMs the same way again.

💸 SPECIAL OFFER: Newsletter subscribers receive 10% off any Validation Institute service. Use code FIDUCIARY10 at checkout.

📬 PAY IT FORWARD: Feel free to forward this offer to your broker, PBM, or other vendors. Don’t hesitate to tell them you will favor validated vendors as part of your modernized procurement processes. Strong compliance and better benefits begin with validation.

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Don’t be a bystander. Change the status quo and reap the benefits of The Health Plan Compliance Advantage.
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