Between now and December, many companies will sign or renew agreements with the vendors behind their benefits, from pharmacy benefit managers to stop-loss carriers.
This year, those signatures come with a new right.
A federal law passed in February requires many of those vendors to tell you, in writing, how they are paid before you sign.
See what changed and what you should do over the next 90 days.
What Changed
Since 2021, brokers and consultants expecting to earn $1,000 or more from a group health plan have had to disclose their compensation.
The Consolidated Appropriations Act, signed February 3, 2026, extended that requirement to nearly every type of vendor a health plan pays.
The disclosure covers what your plan pays the vendor directly and what the vendor earns from other sources, such as rebates or bonuses.
It applies to any contract you sign, extend or renew after February 3, 2026.
Does this include my…?
- Pharmacy benefit manager (PBM)
- Third-party administrator (TPA)
- Stop-loss carrier
- Dental and vision carriers
- Wellness and disease management programs
- Employee assistance program (EAP)
- Benefits administration platform or transparency tool
- Medical management vendor
If a vendor fits one of these categories and expects $1,000 or more from your plan, the answer is yes.
Why It Matters Now
Two things make this fall different.
- Courts are paying closer attention. Employee lawsuits over health plan costs have often been dismissed. In March 2026, a federal court in New York let one move forward, in part because the employees could point to specific overpayments. Clear records of what your plan pays, and to whom, are now a core part of good plan oversight.
- Contracts last longer than you think. New pharmacy rules take effect for calendar-year plans on January 1, 2029. PBMs will have to pass 100% of drug rebates back to the plan and provide regular reports on pricing and fees. A three-year PBM contract signed this fall will still be in force when those rules arrive, so building them in now saves a harder conversation later.
Your Before-You-Sign Checklist
- List every contract up for renewal. Include each health plan vendor signing, extending or renewing before January 1.
- Ask each vendor, in writing, how it is paid. Request a description of services, whether the vendor acts as a fiduciary, and all direct and indirect compensation. Keep a dated copy of your request on file.
- Compare the disclosure to the contract. Summaries and fee schedules do not always match. A line-by-line review catches charges that are easy to overlook.
- Add reporting and audit rights now. Language covering the 2029 pharmacy rules is simple to add before signing and harder to add after.
- Keep one compliance calendar. Place vendor disclosures alongside ACA reporting, COBRA, required notices and the gag clause attestation due December 31.
- Know your next step if nothing arrives. If a vendor does not respond to a written request, talk with your ERISA counsel about options, including notifying the Department of Labor.
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