By 2027: ✅ 75% will rebid their PBM ✅ 35% will conduct acquisition-cost analyses ✅ 33% will partner with a new or emerging PBM
WTW Highlights: Emerging PBM Strategies
For years, employers were told to sit tight while Washington sorted it out.
Now they’re taking matters into their own hands by demanding transparency, competition, and real fiduciary accountability.
The market is finally responding.
Fiduciary pressure and economic reality have converged.
A New Kind of PBM Model
As employers move, innovators are redesigning the system itself.
One of them is Pramod John, CEO of VIVIO, a Public Benefit Corporation, and a Nautilus advisor. A recognized industry thought leader, Pramod has consistently challenged the PBM industry to evolve beyond its legacy business models.
He reminds us meaningful reform won’t come from tweaking old systems. It requires building new ones designed to serve plan sponsors first.
“You can’t fix a broken system with the same incentives that broke it. The only way forward is to build PBMs with a new business model making money by lowering costs, not hiding them.” — Pramod John, CEO VIVIO
Transparency alone isn’t enough. If incentives remain misaligned, “transparency” becomes just another marketing term. Real progress happens when PBMs design their outcomes around fiduciary alignment, where employer success and PBM success are measured the same way.
That vision aligns perfectly with our mission at Nautilus: helping fiduciaries identify PBMs that prove integrity through data and contract structure, not slogans.
Transparency That’s Proven
The shift toward transparent PBMs is welcome. But transparency must be proven.
That’s where contracts come in.
Fiduciary transparency can’t be just a marketing claim. It has to be a standard that can be proven and enforced.
At Nautilus, we’ve built the tools to do exactly that:
Model Contract Language: contract terms that enshrine fiduciary alignment and transparency.
Contract X-Ray™: tools revealing the fine print that hides conflicts and costs.
PBM Configurator™: tools helping employers compare, score, and contract with fiduciary-aligned PBMs.
“Transparency isn’t a marketing slogan. It’s a measurable behavior. And it only matters if it’s built into the business model.” — Pramod John
Key Takeaways
Here’s what this means for employers and fiduciaries:
Employers are reshaping the PBM market faster than legislation ever could.
The movement toward better PBM business models is gaining real traction.
Fiduciary accountability is now a PBM procurement requirement, not a talking point.
The next wave of PBMs will compete on fiduciary alignment, not opacity.
“Employers have more power than they realize. When they demand transparency and alignment, the market moves.” — Pramod John
Action Steps for Employers and Advisors
Here’s how to turn that momentum into action:
Find an unconflicted advisor paid by you, not by the PBM.
Run a Contract X-Ray™ to evaluate your current and future PBM agreements.
Benchmark your metrics as you restructure, rebid, or replace your PBM.
Ask vendors to attest their support for fiduciary-aligned model contract language.
The Bottom Line
Employers are moving on. And they’re not looking back.
The good news? There are plenty of fiduciary-aligned PBMs in the sea.
The better news? Employers now know exactly what they deserve: transparency, alignment, and proof.
PBMs, it’s not us. It’s definitely you.
It’s Totally You!
Call to Action: Join the Nautilus Proof Movement
📄 Send us your PBM contract → We’ll run a Contract X-Ray.
📊 See how it compares to fiduciary-grade standards.
🤝 Collaborate with lawyers, advisors, and PBMs who build from the same blueprint.
Be part of the proof, not the problem.
Note of Appreciation
Pramod John
Pramod John is the CEO of VIVIO a public benefit corporation and a valued contributor to the Nautilus Health Institute. VIVIO is reinventing the therapeutic use and supply chain for the specialty drug industry by challenging the current framework of efficacy and extending it to true effectiveness in the real world.
Visit nautilushealth.org/pbmto find educational resources, procurement tools, model contract terms, the PBM Configurator, and other tools.
💸 SPECIAL OFFER: Newsletter subscribers receive 10% off any Validation Institute service. Use code FIDUCIARY10 at checkout.
validationinstitute.com
📬 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.
Don’t be a bystander. Change the status quo and reap the benefits of The Health Plan Compliance Advantage.
