What Rebate Pass-Through and New Reporting Rules Mean for Plan Sponsors
In early 2026, Congress passed sweeping pharmacy benefit manager reform as part of the federal budget package. While the law includes several provisions, two stand out for employers and benefits leaders:
- Mandatory 100% rebate pass-through
- New detailed reporting requirements
These changes are designed to bring more transparency and alignment to how pharmacy benefits are managed. For employers, they create both opportunity and responsibility.
Let’s break down what this means in plain terms.
What Is Rebate Pass-Through?
When a drug manufacturer pays a rebate, it is usually tied to a drug’s placement on a formulary or overall utilization. Historically, PBMs negotiated these rebates. But the way those dollars flowed back to employer plans was not always clear.
Under the new federal law:
- PBMs must pass through 100% of rebates, fees, and price concessions they receive from drug manufacturers to the health plan.
- Rebates can no longer be retained as hidden revenue.
- Payments must be remitted on a regular schedule.
In simple terms, the rebate dollars tied to your plan must now go back to your plan.
Why This Matters
Rebates have long been one of the most misunderstood parts of pharmacy benefit management.
Employers often saw a rebate check but had limited visibility into:
- The total rebate amount negotiated
- Any fees retained by the PBM
- The true net cost of the drug after all concessions
Full pass-through changes the incentive structure. Instead of revenue being tied to rebate retention, compensation shifts toward clearly defined service fees.
That is a significant structural change.
What About the New Reporting Requirements?
The second major reform is transparency.
PBMs must now provide employer health plans with detailed reporting that includes:
- Gross drug spend vs. net drug spend
- Total rebates, discounts, and fees received
- Spread pricing information
- Member out-of-pocket cost data
Reports must be provided at least semiannually, and in some cases quarterly upon request.
For plan sponsors who take their fiduciary responsibilities seriously, this is a big development.
Why Reporting Changes Everything
Data changes conversations. With more standardized reporting, benefits leaders can better answer key questions:
- Are we paying a fair net price?
- Is our PBM’s compensation aligned with our goals?
- Are member out-of-pocket costs improving or rising?
- Are specialty trends being managed appropriately?
Transparency does not automatically lower costs. But it does give employers the tools to evaluate performance in a more objective way.
What Employers Should Do Now
Although implementation is phased in over several years, benefits leaders should begin preparing now.
1. Review Your Current PBM Contract
Understand:
- How rebates are currently structured
- Whether you are already on a 100% pass-through model
- What reporting rights you currently have
Not all “transparent” contracts are created equal.
2. Define What Success Looks Like
Rebate pass-through is important. But net cost matters more.High rebates do not always equal lower overall spend. The goal should be total cost control, improved outcomes, and better member experience.
3. Prepare to Use the Data
Receiving reports is one thing. Knowing how to interpret them is another.
Benefits leaders may need:
- A standardized internal review process
- Independent analytics support
- A clearer dashboard that separates gross, net, specialty, and trend data
Transparency only works if it is acted upon.
The ProCare Rx Perspective
At ProCare Rx, transparency has never been a trend. It has been a foundation.
Long before federal reform required 100% rebate pass-through and detailed reporting,
ProCare Rx built its model around:
- Clear rebate structures
- Defined service fees
- Straightforward net cost reporting
- Clinical programs that focus on total drug spend, not just rebate volume
The goal is simple: align incentives with employer outcomes.
Rebates matter. But real pharmacy value is measured by overall cost control, member safety, and thoughtful clinical oversight.
As federal reforms roll out over the next several years, employers should not just ask, “Are we compliant?” They should ask, “Are we aligned?”
Transparency is no longer optional in this industry. It is the new standard. And for employers who want to lead, not just react, this is an important moment to evaluate whether their PBM model truly supports their long-term strategy.
SOURCES:
https://www.mintz.com/insights-center/viewpoints/2146/2026-02-06-congress-passes-landmark-pbm-reform-2026-spending-bill
https://www.sentinelgroup.com/resource-center/2026/congress-passes-pbm-reform-caa-2026
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










