{
    "schema": "amendsignal.record/1",
    "generated_on": "2026-11-03",
    "publisher": {
        "name": "AmendSignal",
        "url": "https://amendsignal.com/"
    },
    "notice": "Coverage is limited, so a missing record does not mean nothing changed. General information, not legal advice. Check the official source. Please cite the record's url.",
    "change": {
        "id": 31,
        "url": "https://amendsignal.com/changes/employee-benefits-security-administration-proposes-pharmacy-benefit-manager-fee-disclosures/",
        "title": "Employee Benefits Security Administration proposes pharmacy benefit manager fee disclosures for self-insured health plans",
        "change_type": "proposed_rule",
        "change_type_label": "Proposed rule",
        "status": "proposed",
        "status_label": "Proposed",
        "status_statement": "As of our last check on November 3, 2026, this is a proposal, not a requirement. Comments closed April 15, 2026.",
        "significance": "Proposed, nothing required yet",
        "jurisdiction": {
            "code": "US",
            "name": "United States"
        },
        "authority": {
            "name": "Employee Benefits Security Administration",
            "short_name": "EBSA"
        },
        "identifiers": [
            {
                "type": "fr_document_number",
                "label": "FR document",
                "value": "2026-01907"
            },
            {
                "type": "fr_citation",
                "label": "Citation",
                "value": "91 FR 4348"
            },
            {
                "type": "rin",
                "label": "RIN",
                "value": "1210-AB37"
            },
            {
                "type": "cfr_citation",
                "label": "CFR",
                "value": "29 CFR 2550"
            }
        ],
        "dates": [
            {
                "type": "publication",
                "label": "Published",
                "value": "2026-01-30",
                "precision": "day"
            },
            {
                "type": "comment_close",
                "label": "Comments due",
                "value": "2026-04-15",
                "precision": "day"
            }
        ],
        "in_short": {
            "what_changed": "The Employee Benefits Security Administration, part of the Department of Labor, proposes a rule that would require pharmacy benefit managers, and brokers or consultants affiliated with them, to disclose their compensation in detail to fiduciaries of self-insured group health plans covered by the Employee Retirement Income Security Act (ERISA). The comment deadline has been extended to April 15, 2026.",
            "whos_affected": "Employers that sponsor self-insured or level-funded ERISA group health plans, and the vendors that provide pharmacy benefit services to those plans. Fully insured plans are not covered by the proposal.",
            "what_to_do": "This is a proposal, so it creates no new duties for employers now. Employers with self-insured or level-funded plans may want to comment by April 15, 2026, and begin reviewing their pharmacy benefit contracts."
        },
        "summary": "The Employee Benefits Security Administration proposes requiring pharmacy benefit managers, and brokers or consultants affiliated with them, to disclose their compensation in detail to fiduciaries of self-insured group health plans covered by the Employee Retirement Income Security Act (ERISA). Disclosures would come before a contract is signed or renewed and every six months after, and plans would get a yearly audit right. The proposal creates no obligations yet, and comments are now due April 15, 2026.",
        "business_functions": {
            "state": "limited",
            "functions": [
                {
                    "slug": "benefits",
                    "name": "Benefits"
                },
                {
                    "slug": "legal-and-compliance",
                    "name": "Legal and compliance"
                }
            ]
        },
        "added_on": "2026-11-03",
        "updated_on": null,
        "updates_in_progress": null,
        "last_checked": "2026-11-03",
        "record_url": "https://amendsignal.com/changes/employee-benefits-security-administration-proposes-pharmacy-benefit-manager-fee-disclosures/record.json",
        "what_changed": [
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "The Department of Labor proposes a regulation that would require providers of pharmacy benefit management services, and brokers or consultants affiliated with them, to disclose their compensation to fiduciaries of self-insured group health plans.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2026/01/30/2026-01907/improving-transparency-into-pharmacy-benefit-manager-fee-disclosure",
                        "locator": "SUMMARY",
                        "excerpt": "The Department is proposing a regulation that would require providers of pharmacy benefit management services and affiliated providers of brokerage and consulting services to disclose information about their compensation to fiduciaries of self-insured group health plans"
                    }
                ]
            },
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "Disclosures would be given before the plan enters into the contract and then every six months. For extensions and renewals, 30 calendar days in advance would count as reasonable notice.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2026/01/30/2026-01907/improving-transparency-into-pharmacy-benefit-manager-fee-disclosure",
                        "locator": "D.2. Overview of Covered Service Provider Obligations Under This Proposed Regulation",
                        "excerpt": "The disclosures generally would be provided on an initial basis prior to the self-insured group health plan entering into the service contract or arrangement and then on a semiannual basis thereafter."
                    },
                    {
                        "source": "https://www.federalregister.gov/documents/2026/01/30/2026-01907/improving-transparency-into-pharmacy-benefit-manager-fee-disclosure",
                        "locator": "29 CFR 2550.408b-22(e) (proposed)",
                        "excerpt": "(for extensions and renewals, 30 calendar days in advance is deemed to be a reasonable period of time)"
                    }
                ]
            },
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "Plans would gain a right to audit the vendor's disclosures at least once a year. The vendor could not restrict the audit's period, location or number of records, except to limit it to the period the disclosures cover.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2026/01/30/2026-01907/improving-transparency-into-pharmacy-benefit-manager-fee-disclosure",
                        "locator": "29 CFR 2550.408b-22(j)(1) (proposed)",
                        "excerpt": "Not less than once per year, at the written request of the covered plan, the covered service provider shall allow for an audit of the covered service provider for accuracy of any disclosure made to comply with this section."
                    },
                    {
                        "source": "https://www.federalregister.gov/documents/2026/01/30/2026-01907/improving-transparency-into-pharmacy-benefit-manager-fee-disclosure",
                        "locator": "29 CFR 2550.408b-22(j)(6) (proposed)",
                        "excerpt": "The covered service provider may not impose conditions that would restrict the covered plan's right to conduct an audit under this section, including restrictions on the period of the audit, the location of the audit, or the number of records to be provided"
                    }
                ]
            },
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "Fully insured group health plans are excluded, and rules for them are reserved for future action.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2026/01/30/2026-01907/improving-transparency-into-pharmacy-benefit-manager-fee-disclosure",
                        "locator": "D.1.2. Covered Plan--Proposed Paragraph (b)",
                        "excerpt": "The definition of ``covered plan'' in the proposal excludes fully insured group health plans, and disclosure obligations with respect to these plans are reserved for future action."
                    }
                ]
            },
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "As proposed, the rule would take effect 60 days after a final rule is published and would apply to plan years beginning on or after July 1, 2026.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2026/01/30/2026-01907/improving-transparency-into-pharmacy-benefit-manager-fee-disclosure",
                        "locator": "D.11. Proposed Effective and Applicability Dates--Proposed Paragraph (p)",
                        "excerpt": "the proposed rule would be effective sixty calendar days after the date of the publication of the final rule."
                    },
                    {
                        "source": "https://www.federalregister.gov/documents/2026/01/30/2026-01907/improving-transparency-into-pharmacy-benefit-manager-fee-disclosure",
                        "locator": "29 CFR 2550.408b-22(p)(2) (proposed)",
                        "excerpt": "This section shall apply to plan years beginning on or after July 1, 2026."
                    }
                ]
            },
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "The comment deadline was March 31, 2026, and is now April 15, 2026.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2026/03/02/2026-04084/improving-transparency-into-pharmacy-benefit-manager-fee-disclosure-extension-of-comment-period",
                        "locator": "SUMMARY",
                        "excerpt": "The proposed rule was published in the Federal Register on January 30, 2026, with a comment deadline of March 31, 2026."
                    },
                    {
                        "source": "https://www.federalregister.gov/documents/2026/03/02/2026-04084/improving-transparency-into-pharmacy-benefit-manager-fee-disclosure-extension-of-comment-period",
                        "locator": "SUMMARY",
                        "excerpt": "the Department is extending the comment period for an additional 15 days, to April 15, 2026"
                    }
                ]
            },
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "The Consolidated Appropriations Act, 2026, signed February 3, 2026, amended ERISA with new provisions on pharmacy benefit management services. The Department asks commenters whether the proposal should be adjusted in light of those amendments.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2026/03/02/2026-04084/improving-transparency-into-pharmacy-benefit-manager-fee-disclosure-extension-of-comment-period",
                        "locator": "SUMMARY",
                        "excerpt": "On February 3, 2026, the Consolidated Appropriations Act, 2026 amended ERISA to add several provisions relating to providers of pharmacy benefit management services."
                    },
                    {
                        "source": "https://www.federalregister.gov/documents/2026/03/02/2026-04084/improving-transparency-into-pharmacy-benefit-manager-fee-disclosure-extension-of-comment-period",
                        "locator": "SUPPLEMENTARY INFORMATION",
                        "excerpt": "The Department therefore asks interested persons to address, as part of their comments on the proposed rule, whether the rule should be adjusted in light of the CAA, 2026 amendments to ERISA, and if so, what adjustments are needed."
                    }
                ]
            }
        ],
        "who_is_affected": [
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "If finalized, the rule would affect sponsors and other fiduciaries of self-insured group health plans, and certain service providers to those plans.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2026/01/30/2026-01907/improving-transparency-into-pharmacy-benefit-manager-fee-disclosure",
                        "locator": "SUMMARY",
                        "excerpt": "If finalized, this regulation would affect sponsors and other fiduciaries of self-insured group health plans and certain service providers to such plans."
                    }
                ]
            },
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "A covered plan is any ERISA group health plan except one whose benefits are provided entirely through an insurance policy.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2026/01/30/2026-01907/improving-transparency-into-pharmacy-benefit-manager-fee-disclosure",
                        "locator": "29 CFR 2550.408b-22(b) (proposed)",
                        "excerpt": "a ``covered plan'' means a group health plan as defined in section 733(a) of the Act, other than a group health plan in which all of the benefits are provided exclusively through a contract or policy of insurance issued by a health insurance issuer"
                    }
                ]
            },
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "The Department treats level-funded arrangements as self-funded, so plans using them would be covered.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2026/01/30/2026-01907/improving-transparency-into-pharmacy-benefit-manager-fee-disclosure",
                        "locator": "D.1.4. Providers of Pharmacy Benefit Management Services--Proposed Paragraph (c)(1)(i)",
                        "excerpt": "it is common for group health plans to enter into level-funded arrangements that have excessive stop loss policies to emulate characteristics of fully insured arrangements, such as predictable spending, but that are actually self-funded arrangements."
                    }
                ]
            },
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "The disclosure duty would fall on vendors that contract with the plan and expect $1,000 or more in compensation for pharmacy benefit management services, or for related advice when the adviser is that vendor or its affiliate. A third-party administrator that contracts to provide these services would be covered even if another firm performs them.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2026/01/30/2026-01907/improving-transparency-into-pharmacy-benefit-manager-fee-disclosure",
                        "locator": "29 CFR 2550.408b-22(c)(1) (proposed)",
                        "excerpt": "a ``covered service provider'' means a service provider that enters into a contract or arrangement with the covered plan and reasonably expects $1,000 or more in compensation, direct or indirect, to be received in connection with:"
                    },
                    {
                        "source": "https://www.federalregister.gov/documents/2026/01/30/2026-01907/improving-transparency-into-pharmacy-benefit-manager-fee-disclosure",
                        "locator": "D.1.4. Providers of Pharmacy Benefit Management Services--Proposed Paragraph (c)(1)(i)",
                        "excerpt": "If the TPA contracts with the self-insured group health plan to provide pharmacy benefit management services, the TPA would be a covered service provider under this regulation, even if it intends to rely on another provider to perform those services."
                    }
                ]
            },
            {
                "kind": "inference",
                "kind_label": "Our analysis",
                "text": "Health plans of government employers appear to fall outside the proposal, because the ERISA rules it builds on do not apply to governmental plans.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2026/01/30/2026-01907/improving-transparency-into-pharmacy-benefit-manager-fee-disclosure",
                        "locator": "Footnote 101",
                        "excerpt": "However, Title I of ERISA specifically does ``not apply to any employee benefit plan if . . . such plan is a governmental plan.''"
                    }
                ]
            }
        ],
        "business_implications": [
            {
                "kind": "inference",
                "kind_label": "Our analysis",
                "text": "Benefits teams at self-insured employers would receive far more detailed pricing and compensation data from pharmacy benefit vendors, and would be expected to use it when selecting and monitoring those vendors.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2026/01/30/2026-01907/improving-transparency-into-pharmacy-benefit-manager-fee-disclosure",
                        "locator": "A. Executive Summary",
                        "excerpt": "The responsible plan fiduciaries would be able to use the disclosures in their process of selecting a provider of pharmacy benefit management services, engaging an affiliated broker or consultant, monitoring these service providers' operations and compliance with contractual obligations"
                    }
                ]
            },
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "Under the proposal, the plan would pay for the auditor, and the vendor would pay the cost of providing the information.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2026/01/30/2026-01907/improving-transparency-into-pharmacy-benefit-manager-fee-disclosure",
                        "locator": "29 CFR 2550.408b-22(j)(4) (proposed)",
                        "excerpt": "The covered plan shall bear responsibility for all expenses related to the selection and retention of the auditor. The covered service provider shall bear the cost of providing the requested information."
                    }
                ]
            },
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "If a vendor failed to comply, the plan fiduciary would keep relief from the prohibited transaction rules only by requesting a correction in writing and, if the vendor did not comply within 90 calendar days, notifying the Department of Labor.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2026/01/30/2026-01907/improving-transparency-into-pharmacy-benefit-manager-fee-disclosure",
                        "locator": "29 CFR 2550.408b-22(n)(1)(iii) (proposed)",
                        "excerpt": "If the covered service provider fails to comply with the written request described in paragraph (n)(1)(ii) of this section within 90 calendar days of the request, the responsible plan fiduciary notifies the Secretary of the covered service provider's failure"
                    }
                ]
            },
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "When an exemption's terms are not met, plan fiduciaries and their service providers may face enforcement action and civil penalties from the Department.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2026/01/30/2026-01907/improving-transparency-into-pharmacy-benefit-manager-fee-disclosure",
                        "locator": "D.9. Consequences of Non-Compliance and Proposed Administrative Class Exemption for Responsible Plan Fiduciary--Proposed Paragraph (n)",
                        "excerpt": "If the terms of an exemption are not satisfied, responsible plan fiduciaries entering into service arrangements with parties in interest to self-insured group health plans, and the parties in interest themselves, may be subject to enforcement action by the Department and imposition of a civil penalty."
                    }
                ]
            },
            {
                "kind": "inference",
                "kind_label": "Our analysis",
                "text": "Existing pharmacy benefit contracts with restrictive audit or confidentiality terms would likely need to be revised if the rule is finalized as proposed.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2026/01/30/2026-01907/improving-transparency-into-pharmacy-benefit-manager-fee-disclosure",
                        "locator": "29 CFR 2550.408b-22(k)(4) (proposed)",
                        "excerpt": "the covered service provider and its affiliates, agents, and subcontractors may not impose restrictions on the covered plan's use of disclosures required under this section"
                    }
                ]
            }
        ],
        "required_actions": [],
        "recommended_actions": [
            {
                "kind": "recommendation",
                "kind_label": "Our suggestion",
                "text": "Consider confirming whether your group health plan is self-insured or level-funded, and which vendor contracts with the plan for pharmacy benefit services.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2026/01/30/2026-01907/improving-transparency-into-pharmacy-benefit-manager-fee-disclosure",
                        "locator": "29 CFR 2550.408b-22(b) (proposed)",
                        "excerpt": "a ``covered plan'' means a group health plan as defined in section 733(a) of the Act, other than a group health plan in which all of the benefits are provided exclusively through a contract or policy of insurance issued by a health insurance issuer"
                    }
                ]
            },
            {
                "kind": "recommendation",
                "kind_label": "Our suggestion",
                "text": "Consider submitting comments, including on how the proposal should fit with the Consolidated Appropriations Act, 2026 amendments.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2026/03/02/2026-04084/improving-transparency-into-pharmacy-benefit-manager-fee-disclosure-extension-of-comment-period",
                        "locator": "DATES",
                        "excerpt": "Comments should be received on or before April 15, 2026."
                    }
                ]
            },
            {
                "kind": "recommendation",
                "kind_label": "Our suggestion",
                "text": "Consider reviewing current pharmacy benefit contracts for audit limits and confidentiality terms the proposal would bar.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2026/01/30/2026-01907/improving-transparency-into-pharmacy-benefit-manager-fee-disclosure",
                        "locator": "29 CFR 2550.408b-22(j)(6) (proposed)",
                        "excerpt": "The covered service provider may not impose conditions that would restrict the covered plan's right to conduct an audit under this section, including restrictions on the period of the audit, the location of the audit, or the number of records to be provided"
                    }
                ]
            },
            {
                "kind": "recommendation",
                "kind_label": "Our suggestion",
                "text": "Consider noting your pharmacy benefit contract renewal dates, since the proposal would require disclosures at least 30 days before a renewal or extension.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2026/01/30/2026-01907/improving-transparency-into-pharmacy-benefit-manager-fee-disclosure",
                        "locator": "29 CFR 2550.408b-22(e) (proposed)",
                        "excerpt": "(for extensions and renewals, 30 calendar days in advance is deemed to be a reasonable period of time)"
                    }
                ]
            }
        ],
        "required_actions_assessment": {
            "state": "assessed",
            "text": "This is a proposed rule. It creates no requirement for employers or plan fiduciaries now. If finalized as proposed, it would apply to plan years beginning on or after July 1, 2026."
        },
        "applicability": [
            {
                "criterion": "where",
                "label": "Where",
                "answer": "United States, nationwide",
                "kind": "fact",
                "kind_label": "From the source",
                "evidence": []
            },
            {
                "criterion": "employer_type",
                "label": "Employers",
                "answer": "Private and nonprofit employers that sponsor self-insured or level-funded ERISA group health plans; fully insured plans are excluded.",
                "kind": "inference",
                "kind_label": "Our analysis",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2026/01/30/2026-01907/improving-transparency-into-pharmacy-benefit-manager-fee-disclosure",
                        "locator": "SUMMARY",
                        "excerpt": "If finalized, this regulation would affect sponsors and other fiduciaries of self-insured group health plans and certain service providers to such plans."
                    },
                    {
                        "source": "https://www.federalregister.gov/documents/2026/01/30/2026-01907/improving-transparency-into-pharmacy-benefit-manager-fee-disclosure",
                        "locator": "D.1.2. Covered Plan--Proposed Paragraph (b)",
                        "excerpt": "The definition of ``covered plan'' in the proposal excludes fully insured group health plans, and disclosure obligations with respect to these plans are reserved for future action."
                    }
                ]
            },
            {
                "criterion": "size",
                "label": "Size",
                "answer": "No plan size threshold; the Department considered and rejected an exemption for smaller plans.",
                "kind": "fact",
                "kind_label": "From the source",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2026/01/30/2026-01907/improving-transparency-into-pharmacy-benefit-manager-fee-disclosure",
                        "locator": "E.13.2. Exempting Smaller Entities",
                        "excerpt": "For these reasons, the Department determined that a small entity exemption would not achieve the intended goals of the proposed rules."
                    }
                ]
            },
            {
                "criterion": "industries",
                "label": "Industries",
                "answer": "All industries for plan sponsors; among service providers, pharmacy benefit managers, third-party administrators and health insurers are most affected.",
                "kind": "inference",
                "kind_label": "Our analysis",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2026/01/30/2026-01907/improving-transparency-into-pharmacy-benefit-manager-fee-disclosure",
                        "locator": "E.7.2. TPAs and Issuers",
                        "excerpt": "The Department also estimates that the proposed rule will affect 205 TPAs and 373 issuers (i.e., health insurance companies) in the group market"
                    }
                ]
            },
            {
                "criterion": "functions",
                "label": "Functions",
                "answer": "Benefits and legal or compliance teams that select and monitor pharmacy benefit vendors.",
                "kind": "inference",
                "kind_label": "Our analysis",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2026/01/30/2026-01907/improving-transparency-into-pharmacy-benefit-manager-fee-disclosure",
                        "locator": "A. Executive Summary",
                        "excerpt": "Self-insured group health plan sponsors and other fiduciaries who are responsible for prudently selecting and monitoring service providers (referred to herein as ``responsible plan fiduciaries'')"
                    }
                ]
            },
            {
                "criterion": "applies_if",
                "label": "Applies if",
                "answer": "Your ERISA group health plan is not fully insured and contracts with a vendor expecting $1,000 or more for pharmacy benefit management services.",
                "kind": "fact",
                "kind_label": "From the source",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2026/01/30/2026-01907/improving-transparency-into-pharmacy-benefit-manager-fee-disclosure",
                        "locator": "29 CFR 2550.408b-22(c)(1) (proposed)",
                        "excerpt": "a ``covered service provider'' means a service provider that enters into a contract or arrangement with the covered plan and reasonably expects $1,000 or more in compensation, direct or indirect, to be received in connection with:"
                    }
                ]
            },
            {
                "criterion": "action",
                "label": "Action",
                "answer": "Nothing required yet; consider commenting by April 15, 2026.",
                "kind": "recommendation",
                "kind_label": "Our suggestion",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2026/03/02/2026-04084/improving-transparency-into-pharmacy-benefit-manager-fee-disclosure-extension-of-comment-period",
                        "locator": "DATES",
                        "excerpt": "Comments should be received on or before April 15, 2026."
                    }
                ]
            }
        ],
        "open_questions": [
            {
                "question": "Will the Department change the proposal to align with the Consolidated Appropriations Act, 2026 amendments on pharmacy benefit management services?",
                "context": "The extension notice says the new law added disclosure, rebate pass-through and audit provisions, and asks commenters whether the rule should be adjusted."
            },
            {
                "question": "How much would the proposal cost employers that sponsor self-insured plans?",
                "context": "This record does not cover sections E.10 and E.11 of the rule (its benefit, transfer and cost estimates)."
            },
            {
                "question": "How far in advance would vendors have to give notice of material formulary changes?",
                "context": "The proposal does not set a number of days, and the Department says it is considering 75 days."
            }
        ],
        "events": [
            {
                "event_type": "originating_action",
                "label": "Issued",
                "occurred_on": "2026-01-30",
                "summary": "Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure",
                "source": "https://www.federalregister.gov/documents/2026/01/30/2026-01907/improving-transparency-into-pharmacy-benefit-manager-fee-disclosure"
            },
            {
                "event_type": "extension",
                "label": "Extended",
                "occurred_on": "2026-03-02",
                "summary": "Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure; Extension of Comment Period",
                "source": "https://www.federalregister.gov/documents/2026/03/02/2026-04084/improving-transparency-into-pharmacy-benefit-manager-fee-disclosure-extension-of-comment-period"
            }
        ],
        "corrections": [],
        "sources": [
            {
                "label": "Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure, 91 FR 4348 (January 30, 2026)",
                "publisher": "Federal Register",
                "role": "primary",
                "url": "https://www.federalregister.gov/documents/2026/01/30/2026-01907/improving-transparency-into-pharmacy-benefit-manager-fee-disclosure",
                "pdf_url": "https://www.govinfo.gov/content/pkg/FR-2026-01-30/pdf/2026-01907.pdf"
            },
            {
                "label": "Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure; Extension of Comment Period, 91 FR 10033 (March 2, 2026)",
                "publisher": "Federal Register",
                "role": "amendment",
                "url": "https://www.federalregister.gov/documents/2026/03/02/2026-04084/improving-transparency-into-pharmacy-benefit-manager-fee-disclosure-extension-of-comment-period",
                "pdf_url": "https://www.govinfo.gov/content/pkg/FR-2026-03-02/pdf/2026-04084.pdf"
            }
        ]
    }
}