About the Course
Introduction
This CLE webinar will closely examine the landmark legislation in the recently enacted Consolidated Appropriations Act, 2026, with new requirements for pharmacy benefit managers (PBMs) to increase transparency under additional federal oversight. The panel will discuss how counsel may guide covered stakeholders through expansive new obligations and prepare for compliance.
Description
The recently enacted Consolidated Appropriations Act, 2026 (CAA 2026) contains landmark reforms for PBMs. The legislation is a culmination of years of prior legislative and regulatory attempts to increase transparency and oversight of PBMs, drawing from the PBM Reform Act of 2025 and other legislative proposals, and will change longstanding industry practices.
CAA 2026 PBM reforms focus on a number of areas, including increased transparency, standardized reporting, expanded federal oversight, and rebate pass-through. For example, CAA 2026 requires commercial PBMs to remit 100% of all rebates, discounts, fees, and other remuneration received from any applicable entity to the group plan sponsor on a quarterly basis. The law also requires PBMs to provide plans with detailed reports on a semiannual basis (or quarterly upon request) covering a number of categories of information including gross and net prescription drug spending by the plan; manufacturer rebates, fees, and other remuneration received by the PBM in connection with the plan; and a summary document to the health plans to be provided to individual participants and beneficiaries upon request containing information about the plans' prescription drug coverage and spending.
Even though the law's provisions have delayed effective dates and may be subject to future regulatory guidance, counsel should understand how the law will impact covered stakeholders and help them to begin assessments of current contracts and data infrastructure to begin preparing for compliance.
Listen as our expert panel guides healthcare counsel through the expansive new requirements for PBMs and offers best practices for compliance.
Presented By
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Ms. Carnegie has extensive experience advising clients on all aspects of the pharmaceutical supply chain. Her practice involves advising industry stakeholders on a range of business, legal, transactional, and compliance matters. Ms. Carnegie combines her multilayered industry knowledge with a deep understanding of applicable federal and state legal frameworks, in particular federal and state fraud and abuse laws. She provides clients with strategic counseling and creative business modeling that considers legal restrictions and regulatory risk in light of innovation and business goals.
Ms. Keller advises clients in the health insurance industry, including managed care organizations, PBMs, and integrated delivery systems, ACOs, and providers on a variety of regulatory, fraud and abuse, and business planning matters. Her practice centers on compliance with federal healthcare program regulatory requirements, with a focus on reimbursement issues and value-based contracting. Ms. Keller regularly counsels clients regarding risk-adjusted reimbursement programs and the practices that support them, including Medicare Advantage Organizations and ACOs participating in the Medicare Shared Savings Program. She has experience conducting and defending investigations regarding fraud and abuse issues, including billing compliance related to Medicare, Medicaid, and TRICARE. She also works closely with discount medical plans and other clients in the health care industry on matters relating to compliance with state regulations. Ms. Keller is interested in value-based healthcare and works closely with payors, providers, and ACOs, on a variety of innovative collaborations and has experience negotiating and papering these relationships.
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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Date + Time
- event
Wednesday, April 15, 2026
- schedule
1:00 p.m. ET./10:00 a.m. PT
I. Introduction
A. History of PBM legislation and regulation
II. Overview of CAA 2026 PBM reform/requirements
A. Purpose
B. Effective date(s)
C. Commercial market (group health plans and health insurance issuers)
D. Medicare Part D
E. Interaction with/impact on DOL's proposed PBM fee disclosure rule; other regulations
F. Rulemaking and enforcement
III. Compliance challenges
IV. Best practices for helping clients prepare for compliance
V. Key takeaways
The panel will review these and other important considerations:
- What are the new requirements for PBMs related to the commercial market?
- What are the new requirements for PBMs related to Medicare Part D?
- How will the new legislation interact with/have an impact on existing legislation or rulemaking such as DOL's proposed PBM fee disclosure rule?
- Counsel should encourage their clients who are applicable stakeholders to begin doing what now to prepare for compliance?
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