Key Takeaway: CAA 2026 gives plan sponsors stronger rights to see PBM compensation and rebate arrangements, but disclosure alone is not readiness. Plans must ensure their contracts provide meaningful access to data, then use that visibility to evaluate decisions, conflicts and performance.
CAA 2026 became law in February. Most group health plan PBM reporting and rebate pass-through requirements take effect for plan years beginning on or after August 3, 2028—January 1, 2029, for calendar-year plans.
That sounds far away. It isn’t. A PBM agreement signed today may still be in force when those requirements take effect. The contracting cycle makes this urgent, not the compliance date.
When you hear a PBM call itself CAA 2026 ready, what does that mean to you?
At a technical level, it means meeting a new standard for transparency. But we hear that word a lot in this industry, and it’s been used so broadly that it can mean almost anything.
If transparency is going to mean something, it has to be specific and verifiable. The plan should be able to see what it paid, what the PBM and its affiliates retained, where rebates, fees, discounts and other compensation went, and verify it independently.
For years, plan sponsors were asked to trust financial arrangements they couldn’t fully see. CAA 2026 gives them more power to question what they find. But transparency isn’t the outcome. It allows you to ask better questions.
A contract can show where the money went and what the PBM committed to do. It can’t tell you whether the benefit improved health outcomes, prevented avoidable harm or reduced waste. Plan sponsors will have more data. Then what?
PharmPix was built long before CAA 2026. What did you put in place then that matters now?
We didn’t begin with contract language. We began at the pharmacy counter, where we watched prescriptions get processed correctly and still be wrong for the person receiving them. The claim was clean. The therapy wasn’t. Nothing was built to catch the difference, so we built it ourselves.
That taught us a pharmacy benefit has to do more than process a transaction. It has to explain why decisions were made and what happened when something didn’t look right. Transparency came with that. It wasn’t a feature we added in response to a law. It was a consequence of building a system that had to explain its decisions.
We also built the business around that principle. We don’t own pharmacies, so our economics don’t depend on moving prescriptions into a PharmPix-owned channel. We use a separate rebate aggregator, and clients can detach that service or bring their own pharmacy contracts.
That distinction becomes more complicated in a vertically integrated model, where the PBM, rebate aggregator and pharmacies may all sit within one corporate family. Transparency has to extend to every affiliate participating in the economics.
Disclosure can reveal a conflict. It can’t remove one. That’s the question I’d put to any PBM: Is transparency something you added to your contract, or is it built into how your company works?
You've said that if the therapy is right and the member is receiving the right care, the savings follow.
Yes. The lowest drug price isn't always the lowest total cost. Preventing duplicate therapy, correcting an unsafe dose, closing a treatment gap or helping a member stay on an essential medication can reduce avoidable waste for the plan and medical risk for the member.
Value is created when the right person receives the right therapy, and the plan can see the difference it made.
This is a business. But it's a business of health.
More disclosure means more responsibility. What should plan sponsors ask?
CAA 2026 is written around disclosure. But disclosure isn't the point. Plan sponsors can't meet their duty to the people in the plan while blind. The law gives them sight. But sight isn't the duty. Acting on what you see is, and that's the part a contract can't hand you.
Ask your PBM: How many drug-related problems did you identify last month? How many were resolved before the medication was dispensed? What changed for the member?
Ask why a drug received preferred formulary placement, where treatment gaps persist and whether members are abandoning prescriptions because they can't afford them.
Then ask the question the plan sponsor ultimately has to answer. If a participant challenged a decision this plan made about their medication, could you show how it was made? The duty belongs to the plan. The record it depends on comes from the PBM.
If the answers stop at spending, discounts and rebates, the plan may understand the money. It still doesn't understand the care.
So is CAA 2026 readiness a contract question or not?
It starts there. The contract sets what you're entitled to see and what you're allowed to do about it. That's real, and plenty of contracts still fail it.
But readiness is what comes after. No plan is going to be judged on the contract it signed. It'll be judged on what it did with what that contract let it see.
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