In mid-April 2026, a bipartisan coalition of 45 State Attorneys General (AG) submitted a formal letter to the U.S. Department of Labor (DOL) expressing their collective support for a proposed rule (Improving Transparency into Pharmacy Benefit Manager Fee Disclosure, or RIN 1210-AB37). If enacted as drafted, the rule will require pharmacy benefit managers (PBM) to disclose their compensation arrangements to plan sponsors as a condition of satisfying the “reasonableness” requirement of ERISA’s prohibited transaction exemption — effectively embedding fee transparency into routine pharmacy benefit manager (PBM) contracting procedures. Click here to continue reading the full version of this alert.