By Steve Ditto
Everyone’s a “Transparent PBM” Until It’s Audit Time. Marketing says “transparent.” Reality says… prove it.
We’re building a crowd-sourced definition of what true PBM transparency looks like—based on fiduciary duty, contract terms, and pricing practices.
Here’s what we’ve got so far:
• 💰 Admin fees as the only source of revenue
• ✅ 100% rebate and manufacturer payment pass-through
• 🔢 One MAC list
• 🚫 No spread pricing, clawbacks, or DIR fees
• 🕵️♂️ Real-time access to claims and pricing data
• 🧾 Audit rights with extrapolation and invoice-level detail
• 🧠 Formulary based on lowest net cost—not highest rebate
• 🎯 KPIs for getting the right participant the right drug at the right cost
• 📉 Performance guarantees for maintaining or reducing costs
• 📜 Simple, clean contracts that explain how they get paid
• ⚖️ Alignment with ERISA and CAA fiduciary requirements
What did we miss? What doesn’t belong? Let’s build the real transparency standard—so employers stop falling for fake ones.
