PBM Sends RiskManagers An Unsolicited Kickback

As a fee based insurance consultancy, you can imagine our surprise when we opened a letter sent to us in February 2020 from a PBM and found an unsolicited commission check made payable to RiskManagers.

Attached to the check was an accounting showing $1.25 paid per claim on a new account we picked up recently. A commission of $1.25 per prescription can add up fast.

For example, a 2,500 life case would produce, on average, +$45,000 per year in PBM kickbacks labeled commissions.

How often do insurance brokers and consultants receive undisclosed PBM kickbacks? How prevalent is it?

I returned the check with the following letter:


I am returning a check I received from (Name of PBM) for “commissions” earned on the (Name of Group) account. As a fee based insurance consultant, I do not receive any remuneration whatsoever, either directly or indirectly, from any other source other than clients who retain my services.

These monies should be returned to (Name of Group). Going forward, if the $1.25 per claim fee is imbedded in your administration fee, (Name of PBM) should reduce the administration fee by that amount. If the fee is an add-on fee to each prescription claim, then (Name of PBM) should discontinue the fee.

Since the commissions sent represent the months of (Month) through (Month), an accounting must be made for all subsequent months and appropriate refunds returned to (Name of Group).



Bill Rusteberg


To date, the PBM has not responded. So I sent a followup inquiry this morning. Let’s see if we get a response this time………………….


We received this note from the PBM: “Our investigation confirms that the administration fee for this client included $1.25 per claim commission to RiskManagers.us that should not have been included. We are therefore taking the following action:

  • We are reducing the administrative fee charged to (NAME OF GROUP) from $3.50 per claim to $2.25 per claim and preparing an appropriate contract amendment to reflect this.
  • We are stopping any processes that would result in the issuance of further commission checks to RiskManagers.us with respect to (NAME OF GROUP).
  • We are reconciling the administrative fees that (NAME OF GROUP) has paid thus far so that we can refund or credit to the client any portion representing the $1.25 per claim commission.

Additionally we will be scheduling time to meet with (NAME OF GROUP) next week to review these items and answer questions.