Just Add Your Name
The DOL proposed rule on PBM compensation disclosure is the first time regulators have asked employers directly: what do you need to see from your pharmacy benefit vendors?
Comments close March 31. Most employers have never submitted a public comment. So we built the tools to make it simple.
Two free resources, ready now:
DOL Sample Comment Letter
A sample employer comment letter you can personalize and submit to the DOL in under 30 minutes.
DOL Comment Strategy
A recommended comment strategy mapping the four areas where the rule should go further: closing the GPO affiliate loophole, requiring a standardized reporting template, aligning the effective date with CAA 2026 implementation, and extending coverage to fully insured plans.
Both are attached to this week’s newsletter. If you missed Monday’s issue, the full analysis is here: Show Me The Math
Fiduciary comments carry more weight than industry lobbyist comments. You are the constituency this rule was designed to serve. The deadline is March 31.
PBMs have already taken their seat. Yours is now ready.
All the best,
P.S. If this is useful, forward it to your CFO or General Counsel. They should be part of this conversation.
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A Note of Appreciation
Shawn Gremminger is President and CEO at the National Alliance of Healthcare Purchaser Coalitions.
Shawn and his team, the coalitions and their leadership, and many individual contributors deserve congratulations and thanks for persevering over many years to pass the most meaningful PBM reform in a generation.
Don’t be a bystander. Change the status quo and reap the benefits of The Health Plan Compliance Advantage. Schedule an introductory call with us.
