The U.S. Senate passed a $1.2 trillion “minibus” spending package, the Consolidated Appropriations Act, 2026, which includes significant employer-focused pharmacy benefit manager (PBM) transparency provisions. If ultimately approved by the House and signed into law, the measure could meaningfully reshape employer oversight of PBM arrangements.
AJ Barbarito weighed in on the legislation, emphasizing that the rebate pass-through requirement would fundamentally alter what constitutes a “reasonable” PBM arrangement. According to Barbarito, any PBM contract that does not pass through 100% of rebates, fees, and other price-related remuneration would fail to meet that standard.