
PBM Reform Within 2026 Appropriations Bill Signed Into Law
Key Takeaways
- Semiannual PBM reporting to employer plans must detail net drug spending, rebates, spread pricing, and benefit designs that steer utilization to PBM-affiliated pharmacies, with beneficiary-accessible summary documents required.
- Starting in 2028, Part D remuneration is restricted to bona fide service fees that are flat-dollar, fair-market-value payments for actually performed services, limiting rebate-linked compensation structures.
Legislation targeting the practices of pharmacy benefit managers (PBMs) was passed by Congress and signed by the President, with the goal of greater transparency and increased pharmacy access.
Key reforms to pharmacy benefit managers (PBM) have been codified as part of HR 7148, the Consolidated Appropriations Act of 2026, which was passed by Congress and signed by President Donald Trump in the Oval Office on February 3, 2026. The bill contains key provisions of HR 4317, the PBM Reform Act of 2025, which aims to foster transparency, increase pharmacy access, and reform the business practices of PBMs within Medicare and Medicaid.1-4
“The abuses of the dominant PBM middlemen are widely recognized, and this landmark federal action reflects the broad, bipartisan commitment to confront and remedy them,” Steven C. Anderson, president and CEO of the National Association of Chain Drug Stores (NACDS), said in a statement from the organization. “This is the most important federal achievement yet for PBM reform, and it will sustain and build momentum for further reforms where needed.5
What Reforms Are in the Legislation?
According to Representative Earl L. “Buddy” Carter (R–GA), who sponsored the original PBM Reform Act of 2025, a series of key initiatives from that bill were included in the Consolidated Appropriations Act.6
Health Plan Transparency
The bill mandates that PBMs provide detailed, semi-annual reporting to employer plans regarding net drug spending, rebates, and “spread pricing” arrangements. Reporting should also include explanations of benefit designs that push patients to utilize a PBM-affiliated pharmacy. Furthermore, the law ensures that summary documents are made available to PBM participants and beneficiaries, ensuring they are knowledgeable about a plan’s drug spending and coverage.6
PBM Accountability for Medicare Part D Beneficiaries
Beginning in 2028, PBMs and their affiliates will be prohibited from receiving remuneration for Part D services other than those determined to be “bona fide service fees.” These fees need to be a flat dollar amount, related to services that were genuinely performed and consistent with fair market value.6
PBMs must also more thoroughly report—on an annual basis—to Part D plan sponsors. These reports must include drug-specific and aggregate data on factors like manufacturer-derived revenue, total gross spending, and average pharmacy reimbursement amounts disaggregated by dispensing channel. Prescription drug plan (PDP) sponsors will also have the right under the new law to conduct annual audits of their PBM to ensure compliance with the agreement terms and information accuracy.6
“Any Willing Pharmacy” Protections
The PBM reforms mandate that, beginning in 2029, Part D sponsors must allow any pharmacy that meets standard contract terms to participate in their network, a policy called any willing pharmacy. Additionally, the Secretary of the Department of Health and Human Services (HHS) is directed to establish standards for “reasonable and relevant” contract terms by April 2028.6
A new category of “essential retail pharmacies” has been established by the bill, including those in rural, underserved, or urban areas with limited access. The HHS secretary must publish a list of these pharmacies and report on their network participation and reimbursement trends.6
Pharmacies will now have an established process to report contract violations with PBMs. PDP sponsors are now explicitly prohibited from retaliating against or coercing pharmacies that submit allegations against them while authorizing penalties for non-compliance.6
What Do These Reforms Mean for Pharmacists?
These reforms are intended to shift the balance of power from PBMs towards individual pharmacies, allowing for increased reimbursement transparency. According to the American Pharmacists Association (APhA), which supported the legislation, pharmacists will now have stronger reimbursement options through Medicare while being able to more sustainably dispense medications.7
Michael D. Hogue, PharmD, FAPhA, FNAP, FFIP, executive vice president and CEO of APhA, explained in a statement that the reforms included in the legislation signal progress towards a modernized payment system that recognizes the essential role of pharmacists in dispensing. Furthermore, they could allow for heightened delivery of pharmacist-based clinical and preventive services that would reduce Medicare costs and improve patient outcomes.7
Still, Hogue and APhA at large note that these reforms should be coupled with legislation that allows for pharmacist-provided care services to be recognized and covered through Medicare. Specifically, HR 3164, the Ensuring Community Access to Pharmacist Services Act, was not included in the Consolidated Appropriations Act of 2026; passage of that bill would ensure that patients have consistent, covered access to essential services provided by pharmacists during the COVID-19 pandemic, like testing, treatment, and vaccinations.7,8
“While these reforms begin to address one of the most significant challenges pharmacists face under Medicare, they represent one part of the broader effort needed to strengthen pharmacy access and fully support patient care,” Hogue said in a statement. “To truly improve health care delivery, Congress and Medicare must also now recognize and pay for the patient care services that pharmacists provide every day.”7
It remains to be seen what the impacts to patients may be from this new legislation. Pharmacists should ensure they remain aware of incoming changes to PBM practices and adjust their workflows accordingly to prevent disruption.
REFERENCES
1. Text - H.R.7148 - 119th Congress (2025-2026): Consolidated Appropriations Act, 2026. (2026, January 30). Accessed February 4, 2026. https://www.congress.gov/bill/119th-congress/house-bill/7148/related-bills
2. Lim D, Chu A. Congress is about to overhaul the drug market. Consumers may never feel it. Politico. Last Updated February 3, 2026. Accessed February 4, 2026. https://www.politico.com/news/2026/02/02/prescription-drug-costs-pharmacy-benefit-managers-00761503
3. Kupar S, Leach B. Trump signs bill to end government shutdown and fund DHS for two weeks. NBC News. Last Updated February 3, 2026. Accessed February 4, 2026. https://www.nbcnews.com/politics/congress/house-path-end-government-shutdown-tuesday-dhs-trump-rcna257138
4. Text - H.R.4317 - 119th Congress (2025-2026): PBM Reform Act of 2025. (2025, July 10). Accessed February 4, 2026. https://www.congress.gov/bill/119th-congress/house-bill/4317/text
5. Historic: Congress passes landmark PBM reform in a 217-214 vote. News Release. National Association of Chain Drug Stores. Released February 3, 2026. Accessed February 4, 2026. https://www.nacds.org/historic-congress-passes-landmark-pbm-reform-in-a-217-214-vote/
6. A new era for patients: Carter celebrates President Trump signing PBM reforms into law. News Release. Office of United States Representative Buddy Carter, Georgia’s 1st District. Released February 3, 2026. Accessed February 4, 2026. https://buddycarter.house.gov/news/documentsingle.aspx?DocumentID=16308
7. APhA-backed reforms pass Congress—Covering pharmacist care must be next. News Release. American Pharmacists Association. Released February 3, 2026. Accessed February 4, 2026. https://www.pharmacist.com/APhA-Press-Releases/aphabacked-reforms-pass-congresscovering-pharmacist-care-must-be-next
8. Equitable community access to pharmacist services. APhA Action Center. Accessed February 4, 2026. https://actioncenter.pharmacist.com/campaign/equitable-community-access-to-pharmacist-services/
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