What benefits leaders need to know about CAA 2026—and why compliance isn't enough.

The Consolidated Appropriations Act of 2026 is the most significant federal PBM reform in years, creating new obligations around rebate pass-through, reporting, audit rights, and fiduciary status. This brief breaks down what changed, why compliant isn't the same as aligned, and what plan sponsors need to do before their next renewal, since most PBM contracts run three years and the decisions made now determine what you're locked into when the law takes effect.