PBM Fiduciary Oversight for Employer Health Plans

PBM oversight requires more than a rebate summary. Plan sponsors should understand administrative fees, retail and specialty economics, manufacturer revenue, rebate definitions, retained amounts and the entities that receive each stream.

Set contract standards for claims and rebate data, audit scope, reporting timing, performance guarantees and remedies. The review should connect financial results with clinically appropriate access and member experience.

Bring PBM performance into the year-round governance calendar. A quarterly review makes it possible to test assumptions and act before pharmacy results become a renewal surprise.