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February 3, 2026
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PBGH Applauds Congress for Passing PBM and Medical Billing Transparency Reforms in Government Funding Package

OAKLAND, Calif., February 3, 2026 – The Purchaser Business Group on Health (“PBGH”), a non-profit coalition representing 40 of the largest and most innovative employers and public purchasers across the country, applauds the 119th Congress for passing into law the most significant reforms in PBM and medical billing transparency in nearly a decade. PBGH has been a vocal leader on PBM reform and transparency for several years.

Taken together, the bipartisan health care reforms in this law will lower health care costs for employers and employees alike, introduce new accountability for PBMs, and will deliver purchasers an unprecedented amount of transparency into their pharmacy benefit plans.

Elizabeth Mitchell, President and CEO, said in a statement: “Affordability has been and continues to be a top priority for PBGH members, and the affordability of prescription drugs is no exception. PBGH, and our forward-thinking members, have been unwavering in our support of commonsense, bipartisan policies that would lower drug costs by reforming the opaque and unresponsive business practices of PBMs. This law does exactly that.”

Mitchell continued, “Although the PBM reforms are garnering much of the attention, the law also has an important reform for medical billing transparency. Purchasers will now be able to see precisely where care is delivered in their claims data, enabling them to make more informed decisions about how to structure their networks, contract directly for high-value care, and build centers of excellence.”

Relevant Resources

Contents of CAA 2026

The health care reforms for the commercial market in the CAA 2026 include:

  • Section 6701: “Oversight of Pharmacy Benefit Management Services
    • Effective August 2028, PBMs must report semi-annually (or quarterly, upon request) detailed, standardized information to employers at the claim, drug, rebate, and pharmacy-levels (consistent with data privacy laws).
    • Reports must be both in plain language and machine-readable format.
    • PBMs that fail to provide required reports to employers can be subject to a $10,000/day noncompliance penalty.
    • PBMs that knowingly provide false information can be subject to a $100,000/item noncompliance penalty.
  • Section 6702: “Full Rebate Passthrough to Plan; Exception for Innocent Plan Fiduciaries”
    • Effective August 2028, PBMs must fully pass through all rebates, fees, alternative discounts, and any other remuneration to employers.
    • PBMs must remit these payments quarterly and return any overpayment discovered through audits.
    • Records of remuneration and disclosure are available by audit at least once per year by employers (or the employer’s designated third party).
    • PBMs and TPAs are clarified as “covered service providers” under ERISA that must, also, disclose their direct and indirect compensation to employers under the CAA 2021.
    • Employers have a safe harbor available to them if their PBM fails to fully pass through rebates, so long as certain conditions are met.
  • Section 6225: “Requiring a Separate ID Number and an Attestation for Each Off-Campus Outpatient Department of a Provider”
    • Health care providers must obtain their own NPI and bill all services under its unique NPI.
    • The provider must submit an attestation affirming compliance with this requirement.

 

About Purchaser Business Group on Health

PBGH is a nonprofit coalition representing 40 private employers and public entities across the U.S. that collectively spend $350 billion annually purchasing health care services for more than 21 million Americans and their families. In partnership with its members, PBGH initiatives are designed to test innovative operational programs and scale successful approaches that lower health care costs and increase quality across the U.S.