Major Shifts in PBM Contracting Landscape: Navigating CAA and Other Policy Developments

PBM reform is taking an even deeper turn, as shifts in the obligations imposed on pharmacy benefit managers (PBMs) are taking place at the federal level, directly impacting PBM prescription drug pricing transparency and compensation structures. On February 3, 2026, Congress enacted into law the Consolidated Appropriations Act of 2026 (CAA), effectively amending the Employee Retirement Income Security Act of 1974 (ERISA), the Public Health Service Act, and the Internal Revenue Code of 1986,... By: Wiley Rein LLP