The regulatory environment for pharmacy benefit managers is shifting faster than it has in years. Federal legislation, new agency rulemaking, FTC enforcement action, and a wave of state-level reform are all moving in the same direction: toward greater transparency, rebate pass-through, and accountability.

Here's what changed at the beginning of 2026, what it means for the industry, and where Rightway stands.

Federal updates.

New federal law establishes transparency and rebate pass-through requirements for PBMs.

In February, Congress enacted sweeping PBM reform as part of the 2026 Consolidated Appropriations Act. The CAA, 2026 covers a wide range of requirements, including new transparency and reporting standards, mandated rebate pass-through for commercial and ERISA plans, and audit rights to enforce compliance. Most provisions take effect in 2028–2029.

What this means for the industry:

• CAA, 2026's mandated reporting and auditing could make it difficult for misaligned traditional PBMs to continue with their current business practices without taking the risk of additional regulatory scrutiny or losing further business.
• Even partially transparent competitors—those that still own affiliated pharmacies or sit within larger conglomerates—will need to move toward what Rightway has been since day one: fully transparent, 100% rebate pass-through, and client-aligned.

What this means for Rightway:

Rightway's model was built to meet these standards before they were required. Our priority now is staying ahead of the evolving implementation guidance.

DOL proposes rule requiring PBMs to disclose fees to plan fiduciaries.

As part of broader executive action on PBM reform, the Department of Labor has proposed a rule requiring PBMs to provide additional transparency to plan fiduciaries on compensation and pricing. The rule is still pending finalization.

What this means for the industry:

• If finalized, the rule would accelerate reporting requirements similar to those in the CAA, 2026—potentially ahead of the 2028–2029 effective dates. For less transparent PBMs, enforcement of this rule may require a re-evaluation of their contract terms, pricing structures, and alignment with them.

What this means for Rightway:

Rightway's transparent model is already aligned with the proposed rule. We'll continue tracking its progress and will communicate any adjustments to clients promptly if the rule goes into effect.

Express Scripts settles FTC insulin pricing suit; CVS Caremark and OptumRx remain in litigation.

In 2024, the FTC sued all three of the largest PBMs—Express Scripts, CVS Caremark, and OptumRx—alleging that their business practices had artificially inflated insulin prices. As of February 2026, only Express Scripts has settled. Under the terms of its agreement with the FTC, ESI must make material changes to its business practices, including on pricing transparency and product access. CVS Caremark and OptumRx are still fighting the suit.

What this means for the industry:

• The settlement reinforces that the Big 3 will remain under heightened regulatory scrutiny for the foreseeable future. The required changes under ESI's settlement mirror the transparency and reporting standards now being mandated more broadly through the CAA, 2026.

What this means for Rightway:

The litigation doesn't affect Rightway directly. Our model was never built around the practices being challenged. Employers working with Rightway don't carry the compliance or reputational exposure that comes with the legacy PBM approach.

State updates.

Illinois bans spread pricing and mandates 100% rebate pass-through.

Illinois HB 1697, which passed in 2025, became effective January 1, 2026. The law bans spread pricing and PBM steering, mandates 100% rebate pass-through, sets a variable price ceiling tied to the least costly available option, and establishes auditing and transparency requirements.

What this means for the industry:

• PBMs operating in Illinois will need to demonstrate compliance, though some obligations are still being defined and will require ongoing monitoring.

What this means for Rightway:

Rightway's model is proactively aligned with the core requirements of the law. We'll continue tracking any additional reporting or operational standards as implementation guidance develops.

Iowa's spread pricing and rebate pass-through law faces legal challenges.

Iowa SF 383, passed in 2025, would ban spread pricing, mandate rebate pass-through, set pharmacy reimbursement requirements, and establish transparency standards. Since its passage, the law has been challenged in court by insurers and PBM industry representatives. Several of its provisions remain blocked pending resolution of those cases.

What this means for the industry:

• The legal battles reflect a tension playing out in several states: reforms that benefit pharmacies and plan sponsors sometimes conflict with reimbursement structures that insurers and PBMs rely on. The outcome in Iowa will likely influence similar legislation in other states.

What this means for Rightway:

We're monitoring the litigation and will evaluate the impact of any final ruling on our operations and clients in Iowa.

Kansas signs PBM reform into law, with legal challenges likely to follow.

The Kansas Consumer Prescription Protection and Accountability Act was signed into law on April 9, 2026. It includes a spread pricing ban, mandated rebate pass-through, auditing procedures, reimbursement requirements, and a Kansas-specific PBM examination process. PBMs actively contested the law during its development, primarily over its reimbursement provisions, suggesting similar legal challenges may follow.

What this means for the industry:

• Kansas joins a growing list of states tightening PBM requirements. The reimbursement provisions are the most contested and most likely to face litigation.

What this means for Rightway:

Rightway is aligned with the core obligations of the law. We'll track any legal developments and adjust if enforcement changes require it.

The bigger picture on PBM legislation updates.

These updates point to a clear direction: the industry is being pushed toward the model Rightway was built on. Full rebate pass-through, transparent pricing, claims-level reporting, and fiduciary alignment will have to become the dominant positions in the industry.

For consultants and brokers, this is a useful lens for evaluating PBM relationships. A client's current PBM may be compliant today, but it will still carry meaningful risk as these requirements take hold. For some PBMs, adaptation will be necessary; it’s just a matter of how much disruption it will create and who it will affect the most.

Rightway will continue publishing quarterly regulatory updates as the landscape evolves. If you have questions about how any of these changes affect a specific client situation, reach out to your Rightway contact directly.

Book a demo today and see how Rightway pharmacy benefit management was built around transparency and fiduciary alignment.