The Consolidated Appropriations Act of 2026 (CAA 2026) represents a meaningful shift in how pharmacy benefit managers (PBMs) are evaluated, monitored, and held accountable. While many organizations are focused on what they need to do to comply, the more important question is what they can do differently because of it. 

For employers, this moment presents both responsibility and opportunity. 

For years, PBMs have played a central role in managing pharmacy benefits—negotiating rebates, processing claims, and overseeing utilization. But for many employers, the system has lacked transparency. 

That has made it difficult to fully understand true costs, revenue flows, and how PBMs are actually compensated. 

CAA 2026 is designed to change that. 

At its core, the legislation gives plan sponsors access to something they’ve historically lacked: meaningful visibility into what they’re paying for—and whether it’s reasonable. But with that visibility comes a higher standard of accountability. 

Importantly, this isn’t all future-state. While many requirements phase in through 2028 and 2029, key elements—particularly PBM compensation disclosure expectations—are already in effect for new and renewing contracts. 

The takeaway? This isn’t something to watch from a distance. It’s a shift that is already underway. 

CAA 2026 reframes the relationship between employers and their PBM partners—moving from limited insight to true oversight. 

Key changes include: 

Taken together, these changes shift the balance of power—giving employers both the data and authority to better understand and manage pharmacy spend. 

It’s also worth noting that while provisions like 100% rebate pass-through are designed to increase alignment, the details matter. Definitions of “rebates” and other forms of compensation will require closer review than in the past. 

“Transparency” is often discussed broadly. Under CAA 2026, it becomes much more specific—and much more actionable. 

This isn’t just visibility into administrative fees. It includes both direct and indirect compensation across the pharmacy ecosystem—spanning manufacturers, wholesalers, rebate aggregators, and other intermediaries. 

In addition, employers will gain access to more granular data than ever before, including: 

In practical terms, this means moving away from estimating and trusting PBM-reported outcomes—and toward validating them with real data. 

For many organizations, that’s a significant shift. It reduces much of the ambiguity that has historically shaped pharmacy strategy decisions. 

One of the most significant implications of CAA 2026 is the expansion of fiduciary responsibility. 

The legislation doesn’t just provide access to new information. It creates an expectation that employers actively review, interpret, and act on it. 

That means: 

Access to data alone will not be enough. 

Employers will be expected to use that information to make informed, defensible decisions—and demonstrate that they’ve done so. 

The question is no longer “Do you have access to this information?” 
It’s “Are you using it appropriately?” 

While full compliance deadlines extend into 2028 and 2029, the window for strategic action is shorter than it may seem. 

When you factor in contract cycles, procurement timelines, and internal approvals, waiting can limit your options. 

The real opportunity is now—while you still have time to shape outcomes, not just react to them. 

Four priorities stand out: 

Navigating CAA 2026 will require more than checking compliance boxes. It will require the ability to interpret complex data, evaluate performance, and make informed decisions in a rapidly evolving environment. 

At MJ, we work alongside clients to move beyond compliance—helping them turn new requirements into smarter decisions and better outcomes. 

We do that by: 

Just as importantly, this new level of transparency opens the door for more collaborative, data-driven conversations with PBM partners, focused on improvement, not assumptions. 

As this landscape evolves, our role is to serve as both a compliance guide and a strategic partner—helping you turn new requirements into measurable advantage. 

While CAA 2026 introduces new requirements, its long-term impact goes much further. 

Organizations that act early can: 

For the first time, employers have the ability to move from limited visibility to true control—using data not just to understand pharmacy spend, but to actively shape it. 

CAA 2026 changes the rules—but it also levels the playing field. As this evolves, federal agencies like the Department of Labor are anticipated to release further guidance to clarify expectations around disclosures and reporting. 

For the first time, employers can fully understand what they’re paying for, why they’re paying it, and whether it’s working. 

The organizations that treat this as a compliance exercise will meet the standard. 

The ones that treat it as a strategic inflection point will redefine it. 

Compliance is the floor. What you build on top of it is what will create advantage. We’re here to help. Reach out to us today to speak to our pharmacy experts.