Brown & Brown urges employers to review PBM contracts for new disclosure requirements

• Brown & Brown urged employers to update PBM contracts for enhanced compensation disclosures covering plan years beginning on or after July 1, 2027.
• The Labor Department’s final rule covers self-funded ERISA plans with at least 100 participants or sponsors averaging at least 100 employees.
• PBMs must provide initial compensation disclosures at least 90 days before contracts begin, renew or extend.
• Ongoing disclosures are due within 30 days of each six-month period; plans can request quarterly reporting.
• Plan fiduciaries must monitor compliance, seek corrections for deficient disclosures and report uncorrected failures to the Labor Department.

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