Consolidated Appropriations Act 2026
The Consolidated Appropriations Act of 2026 (CAA 26), which was signed by the President on February 3, 2026, reshapes how pharmacy benefit managers (PBMs) will operate in the employer group health plan market. The statute creates new federal transparency, reporting, rebate remittance, and fiduciary compliance requirements across the Public Health Service Act (PHSA), ERISA, and Internal Revenue Code, thereby broadly affecting all group health plans.
The legislation aims to:
- Increase transparency into drug pricing, spreads, and rebate flows;
- Ensure that 100% of drug rebates and remuneration are passed back to plans; and
- Expand fiduciary oversight and enforcement mechanisms.
Most provisions take effect for plan years beginning 30 months after enactment (e.g., January 2029 for calendar year plans) and will apply to contracts entered into or renewed after that time. For employers and brokers, these changes may affect PBM contracting, fiduciary oversight, and compliance responsibilities well before the effective date as contracts are reviewed and renegotiated. Read more

