PRA Comment Letter Calls on Labor Department to Expand and Strengthen PBM Disclosure Rule

PRA submitted a public comment letter calling on the U.S. Department of Labor (DOL) to expand and strengthen its proposed Pharmacy Benefit Manager (PBM) Fee Disclosure Rule.

The proposed rule takes a long-overdue step toward bringing transparency to one of the most opaque corners of the healthcare system—PBMs—helping employers better understand where their healthcare dollars are going. But as currently drafted, it does not go far enough to give employers the tools they need to substantially lower costs, increase wages, and improve patient outcomes.

PRA offers five key recommendations:

1) Expand the Rule’s Scope Beyond PBMs to All Group Health Plan Service Providers

PRA urges the DOL to expand the rule to cover all health plan middlemen, including not only PBMs but also third-party administrators (TPAs), and other vendors operating through complex and opaque financial arrangements.

This expansion is critical because PBMs, TPAs, and other third parties are often vertically integrated. Without broader coverage, compensation and inflationary practices can easily be shifted across affiliated entities to avoid scrutiny.

2) Strengthen Disclosure Requirements with Transaction-Level Data

PRA calls for detailed, transaction-level transparency so employers can see the actual flow of funds—not just high-level summaries.

Aggregated reporting can obscure abusive or inefficient practices. Only granular data enables employers to verify true costs and identify conflicts of interest.

3) Expand Claims Data Access and Audit Rights

PRA recommends requiring continuous, real-time access to claims data, along with robust audit rights.

Audits should go beyond summary verification and include payment accuracy, contract compliance, and legal compliance—ensuring employers can fully validate how plan dollars are spent.

4) Align the Rule with CAA 2026 and Clarify HIPAA

PRA calls on the DOL to align the final rule with the Consolidated Appropriations Act of 2026 (CAA 2026) and address a common industry claim that HIPAA restricts data sharing.

PRA emphasizes that health plans are entitled to their own data. HIPAA protects patient information from misuse—it does not permit vendors to withhold data from the plan that owns it.

5) Expand the Economic Analysis of Transparency

PRA recommends expanding the rule’s Regulatory Impact Analysis to better capture the full economic benefits of transparency.

Increased transparency can reduce healthcare spending, strengthen employer negotiating power, improve business competitiveness, and ultimately lead to higher wages for workers—not just better health outcomes.