Five Questions Your PBM RFP Should Contain
Choosing a pharmacy benefit manager is about more than comparing discounts and rebate guarantees. The request for proposal should help employers and benefits consultants understand how each offer will work after the contract begins
.
The best questions require clear, written answers that can be measured, audited, and added to the final agreement. As you evaluate your pharmacy plan design, make sure your RFP addresses these five areas.
1. Can We Audit Every Part of the Pharmacy Benefit?
A simple “yes” is not enough.
Ask whether the plan can review claim-level data, pricing, rebates, fees, and payments involving subcontractors or downstream vendors. The plan should be able to choose an independent auditor, use a reasonable lookback period, and share findings with its internal team and advisors.
Federal rules also limit contract terms that block group health plans from accessing certain claims and cost information. The RFP response should explain the audit process, timing, data format, and what happens when an error is found.
2. Is Pricing Fully Pass-Through Across Every Channel?
Pricing may work differently at retail pharmacies, mail-order pharmacies, and specialty pharmacies.
Ask the PBM to state, in writing, whether it keeps any spread between what the plan pays and what the pharmacy receives. The answer should cover every dispensing channel and any related company.
Also ask the bidder to list all administrative, transaction, clinical program, and other fees. A pricing model is only transparent when every dollar has a clear path.
3. Can We See and Confirm the Net Cost of Each Drug?
A large rebate does not, by itself, prove that a plan has the lowest cost.
Ask each bidder to show the plan’s net cost after rebates, discounts, fees, and other credits. Require drug-level reporting and request a sample report during the RFP process. Then ask how those numbers can be tested after implementation. This helps the evaluation team compare what the plan is expected to spend, not just the size of a rebate guarantee.
4. What Can Change During the Contract?
A strong proposal should explain whether the PBM can change its maximum allowable cost lists, pharmacy network, formulary, pricing rules, specialty drug list, or fees during the contract.
Ask which changes require notice and which require the plan sponsor’s approval. For maximum allowable cost pricing, request a clear appeal process, response deadlines, and access to the data supporting the change.
The contract should also state the plan’s options when a change causes higher costs or disrupts member care.
5. Are All Terms and Payments Clearly Defined?
Words such as “rebate,” “ingredient cost,” “specialty drug,” “pass-through,” and “fee” can mean different things across proposals. Require plain definitions and make sure the same definitions appear in the final contract.
The RFP should also ask brokers and consultants to disclose all direct and indirect compensation tied to the pharmacy benefit. For plans covered by the Employee Retirement Income Security Act, federal rules require certain brokerage and consulting compensation disclosures before a service arrangement is entered into, renewed, or extended.
How an RFP Should Work.
A PBM RFP should do more than identify a winning bidder. It should create the framework for the contract, reporting, and ongoing performance reviews.
Clear questions make proposals easier to compare and reduce surprises later. Before selecting a partner, confirm that every important promise can be measured, verified, and enforced.
Sources:
https://www.dol.gov/agencies/ebsa/about-ebsa/our-activities/resource-center/faqs/aca-part-69
https://www.dol.gov/newsroom/releases/ebsa/ebsa20211230
About ProCare Rx
ProCare Rx is a privately held, independent pharmacy benefit manager (PBM) that has empowered healthcare and self-insured organizations since 1988. We provide fully integrated, in-house solutions—including claims adjudication, clinical program design, pharmacy network access, cost containment, and data analytics—all supported in the U.S. Our flexible, transparent model serves self-insured employers, third-party administrators (TPA), brokers, health plans, health systems, managed care organizations (MCO), unions, workers’ compensation programs, Medicare, Medicaid, hospices, and other PBMs. With a proprietary technology platform, commitment to ethical operations, and a focus on lowest net cost, ProCare Rx delivers long-term value, clinical performance, and trusted pharmacy benefit partnerships.
Media Contact:
Marc Cohen,
SVP, Marketing
marketing@ProCareRx.com










