The first step to fixing your health plan? Admitting you have a problem.
PBMs and brokers built a system to keep employers hooked: opaque contracts, hidden fees, complex pricing, and “discounts” that actually inflate costs.
We’ve been told: “There’s nothing you can do.” “It is what it is.” “We worked hard to limit your increase to 10%.”
Who wants to admit defeat? Practically no one.
But recovery is possible — and it starts with a mindset shift.
Employers must embrace their fiduciary duty.
Because you can’t outsource accountability — only practice it.
PBM Recovery Group
The Problem: Dependency by Design
PBMs are like diet coaches paid per donut sold.
They’ve engineered a world where every rebate means higher list prices, bigger spreads, and more hidden fees. Employers are trapped in a system that rewards bad behavior and calls it management.
No wonder so many employers once had faith, but have lost it.
Some have drifted into indifference. Some have cut themselves off. A few are still convinced they’re on the right path.
Recovery requires belief in a power greater than apathy: fiduciary responsibility.
(Nautilus Edition)
For plan sponsors ready to detox from PBM dependency.
Step 1: Admit Your Plan Has a Problem.
If you can’t explain how your PBM gets paid, that’s your first red flag.
Denial is expensive.
Step 2: Recognize Your Enablers.
If your broker gets paid by the PBM, you’re not getting sound advice.
You’re getting sold.
Step 3: Complexity is a Con. Not a Credential.
Complexity protects PBM profits, not participants.
It makes PBMs unaccountable by design.
Step 4: Don’t Sign Blind. X-Ray the Contract.
The Nautilus Contract X-Ray exposes gaps, hidden costs, and conflicts.
What you can’t see will cost you.
Step 5: Make Them Sweat the Fine Print.
Test your PBM. The Nautilus Compliance RFI reveals if they’re aligned.
Find out who’s allergic to oversight.
Step 6: Test the Market. Not Your Luck.
The Nautilus Market RFI benchmarks PBMs against fiduciary standards.
See who is worthy of trust.
Step 7: Lead With Model Language. No Word Salads.
Seal PBM contract loopholes with Nautilus model contract terms. Validated, enforceable, and built to protect participants.
Step 8: Keep Score. Or Get Played.
The Nautilus Configurator turns feelings into facts.
Because “they seem nice” isn’t a procurement strategy.
Step 9: Stop Saying It. Start Proving It.
Require PBM data feeds, documentation, and fiduciary attestations.
“Trust us” belongs in marketing, not management.
Step 10: Adopt a Participant-First Mindset.
Every dollar, decision, and contract clause should pass the loyalty test. Does it serve the Participant and beneficiaries or the middleman?
Step 11: Document Your Fiduciary Recovery.
Charters, minutes, and audits turn good intentions into governance.
Accountability is the architecture of trust.
Step 12: Celebrate Transparency. Then Verify It.
Recovery isn’t permanent. Review, renew, and re-audit every year.
The cure for relapse is routine oversight.
The PBM Serenity Prayer:
“Grant me the serenity to accept the hidden fees I cannot find,
The courage to audit the ones I can,
And the wisdom to fire those who hide the difference.”
Fiduciary recovery starts with one act of accountability.
Key Takeaways
Fiduciary denial is common — but completely curable.
Misaligned incentives thrive where oversight is optional.
The cure is structure: contracts, audits, committees, and culture.
Embrace your fiduciary responsibility — it’s your recovery plan.
Fiduciary recovery isn’t an event. It’s a discipline.
A Note of Thanks
Renzo Luzzatti
Renzo Luzzatti, CEO of US-Rx Care, has been a long time, outspoken proponent of PBM fiduciary responsibility. Renzo is a Producer of the documentary Side Effects May Include – a raw, unfiltered look at the prescription drug pricing system and the middlemen profiting from America’s pain. Secure your spot for an exclusive screening followed by live Q&A on October 28 at 1 pm CT.
Deep gratitude to everyone who built this toolkit: Nautilus and Health Rosetta leadership, expert advisers, and PBMs committed to transparency.
Explore the model PBM contract language and apply for early access to the Nautilus PBM Configurator at: 🔗nautilushealth.org/pbm
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.
