
Trade group for transparent PBMs has changed its name
Key Takeaways
- CAA 2026 mandates rebate pass-through and at least twice-yearly reporting on spread pricing, acquisition costs, and rebate amounts.
- Enforcement provisions include $10,000-per-day penalties for nondisclosure and $100,000 per knowingly false item, materially raising compliance risk.
Transparency Rising is the new name for Transparency-Rx, a trade group of smaller PBMs challenging the "big 3."
The smaller pharmacy benefit managers (PBMs) that promise more transparent business practices won a major victory earlier this year when a new set of PBM regulations and reporting requirements were included in the Consolidated Appropriations Act of 2026 (CAA 2026).
Now the trade group that represents their interests is changing its name partly from Transparency-Rx to Transparency Rising.
Joe Shields, the CEO of the group, said in an interview with Managed Healthcare Executive (MHE) today the modest shift in naming was partly because the group’s annual meeting is called Transparency Rising. Another factor is that companies that don’t identify as PBMs are interested in getting involved in the group, he said.
“The complexity of the market is becoming more apparent to everybody,” Shields said. I think our membership is beginning to reflect that and so we are drawing in affiliate types of companies that aren’t, as a technical matter, defined as a PBM — or don’t define themselves as a PBM. I’ll leave it to the lawyers to define whether or not they would be subject to PBM laws.”
CAA 2026 reforms include requirements to pass through rebates and disclose information on spread pricing, acquisition costs and rebates at least twice a year. through various reporting requirements. The law also enforcement provision that includes fines of $10,000 per day for failure to disclose required information and $100,000 per item of false information knowingly provided. To complicate matters, the Department of Labor has issued proposed regulations that touch on many of the same issues. The final version of those regulations are likely to be adjusted so they are consistent with the rules that were part of the appropriations act.
The Transparency Rising
The PBM industry is dominated by the “big 3” — CVS Caremark, Express Scripts and Optum Rx. Some industry observers, as well as executives at the big 3, have asserted that the CAA 2026 and the labor department rules, along with Federal Trade Commission settlements, might narrow the difference between the small, transparent PBMs and the big 3 as the big 3 complies with the law. Shields rejected that notion.
“They don't, fundamentally, in terms of their business model, they don't feel like a lot of these rules and considerations are applicable to the way in which they approach pharmacy benefits and the broader supply chain in meaningful ways,” Shields said about the large PBMs. “I do think there's going to be continued to be contrasts and conflicts and differences within the business model of companies operating in a certain fashion versus companies that still, at some level, derive their revenue structure from and their profitability from descendants of spread pricing.”
































