90-Day Deadline: Is Your PBM Platform Ready for Real-Time Transparency?

This year, the warning to “beware the ides of March” might have been better said about April – at least when it came to executive orders (EO) and PBMs.

On April 15th, 2025, President Trump issued an EO that upended how PBMs have functioned for decades. It also started the clock on a 180 day deadline by which all PBMs should be ready to comply with sweeping ERISA (the Employee Retirement Income Security Act) compensation disclosure requirements.

What had previously been trade secrets is now about to be public information. Now every dollar of both direct and indirect revenue will need to be tracked, attributed, and reported, many for the first time.

With little wiggle room PBMs have been left with a choice: you can either embrace this moment as an opportunity to lead, or be left scrambling while others turn transparency into a competitive advantage.

The Clock Is Ticking

Previous regulatory waves gave PBMs breathing room, with 18-24 month implementation periods and delayed enforcement. This allowed your teams the time to figure things out as they went.

Now? You've got only a few months to make fundamental changes to your business infrastructure.

October 12, 2025 marks the deadline for the ERISA compensation disclosure regulations. With just about 90 days left, PBMs will be expected to disclose a level of detail that has historically been kept behind closed doors, including spread pricing, rebate structures, mail-order margins, data monetization, and more.

The urgency is further compounded by the ongoing monthly machine-readable file (MRF) updates entering a stricter enforcement phase at nearly the same time. For PBMs, that means simultaneous accountability on two fronts:

1. disclosing every dollar of direct and indirect compensation under ERISA, and

2. publishing clean, standardized, machine-readable pricing data across vast partner networks under the updated Transparency in Coverage (TiC) Final Rules.

The Market Is Already Moving

It’s more than just regulatory requirements driving transparency – as part of the December 2024 government funding bill, Congress passed bipartisan-supported legislation requiring PBMs to deliver 100% rebate pass-through and enhance reporting transparency.

Since 2016, all 50 states have passed some form of PBM regulations, totaling more than 150 laws overall. High-profile health plans, such as Blue Shield of California with its nearly 5 million members, are increasingly choosing transparency-focused alternatives over traditional PBMs.

Mix all of these market changes with advancing FTC lawsuits, and it's clear that transparency is no longer optional.

It’s Time To Choose Your Path

The writing is on the wall and PBM platforms now face a choice:

Option 1 - Reactive compliance with minimum viable transparency to avoid penalties

Option 2 - Proactive leadership using strategic transparency as competitive differentiation

Plan sponsors are demanding clarity and born-digital PBMs with transparency-first models will likely begin to siphon market share. Traditional players that delay will be left defending shrinking margins and eroding trust.

The ERISA Challenge Is More Complex Than You Think

Under ERISA, all companies that provide services to employer health plans must disclose their compensation arrangements to the plan's fiduciaries. Part of the April 15th EO directed the Department of Labor to strengthen these requirements for PBMs specifically and focused on both "direct and indirect compensation."

This means sharing much more than just administrative fee structures.

What You'll Need to Disclose

1. Direct compensation

• Which includes per-prescription processing fees, network access charges, clinical services fees, technology platform costs, and implementation expenses.

2. Service-based revenue

• This covers formulary management consulting, clinical program development, specialty pharmacy management, mail-order fulfillment margins, and patient assistance program administration.

3. Indirect compensation

• It’s this form of compensation where disclosure becomes significantly more complicated.
• It requires disclosing information including generic manufacturer payments, market share bonuses, volume incentives, educational grants, and data licensing revenue.
• All rebates for brand name drugs and whether they are retained or passed through must also be documented and released.
• Additionally, pharmacy network revenue including spread pricing, network administration fees, preferred pharmacy placement fees, audit recovery charges, and performance bonuses must be tracked and reported.

The Documentation Reality Check

Every revenue source previously mentioned must be tied to specific transactions. Those transactions also require real-time attribution to the appropriate plan sponsors.

That means you’ll need a system that can manage complete audit trails, automated report generation, and standardized formats for consistent disclosure.

The Technical Challenge Is Real . . . and Expensive to Get Wrong

Most current PBM platforms process transactions in batch mode with overnight reconciliation. Yet, these new transparency requirements demand real-time capture, categorization, and attribution of every revenue-generating transaction across disparate systems.

While not strictly necessary, a key feature to include is having user-facing dashboards. This provides stakeholders immediate access to compensation details, helps make complex data understandable, and reduces response time when issues or audits arise.

Legacy PBM systems simply aren't built for this. Batch processing and siloed data models can’t handle the sub-second attribution or regulator-ready disclosure needed for success. Adding manual processes on top of these platforms is risky and ultimately expensive to scale.

Common Pain Points And What Happens If You Ignore Them

Whether you're a CTO managing tangled infrastructure, a CPO wrestling with product roadmap trade-offs, or an EVP focused on revenue and retention, the challenges are shared:

• Data: Disparate systems across rebates, claims, accounting, and pharmacy networks create blind spots that regulators will no longer overlook and excuse.
• Reporting: Compliance demands standardized, real-time, and regulator-ready outputs.
• Operations: Without automation, even accurate reporting slows down service teams, increasing costs and delaying value.
• Market exposure: The first transparency misstep becomes a headline, and plan sponsors are already watching.
• Vendor overload: Fragmented point solutions create more integration headaches and more room for error.

What Your Technology Stack Needs

• Event-driven architecture that captures revenue at the transaction level – from rebates, fees, margins, and more – all at sub-second speeds.
• Immutable audit trails and automated reporting that reduce your exposure and increase confidence.
• Plan sponsor self-service portals with intuitive dashboards and drill-down access that reinforce trust.
• Compliance workflows that are integrated into operations, so reporting is mostly automated and significantly less burdensome.
• Scalable cloud-native systems that flex to meet demand surges, with security frameworks already in place.

Why Generic Technology Consulting Won't Cut It

The complexity of PBM workflows and the pressure of the aggressive regulatory timeline means there’s little room for on-the-job learning or trial-and-error approaches.

Delivering the necessary elements for PBM transparency requires an understanding of the industry’s regulatory complexity, technical architecture demands, and the stakeholder-specific interfaces that provide the best user experience.

The Domain Knowledge Problem

With around 90 days left until the EO’s deadline, you need a team that’s handled the unique intersection of regulatory complexity that includes ERISA fiduciary duties, HIPAA privacy requirements, and state pharmacy laws alongside technical architecture demands for real-time data processing, multi-system integration, and enterprise-scale performance.

Generic consultants face terminology barriers with specialized PBM language and its workflow complexity that requires an understanding of claims adjudication and rebate processing. Many won’t have tackled integration challenges with healthcare systems and pharmacy networks or handled regulatory nuance that extends beyond technical implementation to fiduciary responsibilities.

The Praxent Difference: PBM Expertise That Delivers

Praxent isn’t new to this. We’ve delivered enterprise-scale modernization for PBM platforms covering over 25 million people with transparency compliance built into its core.

Our approach combines planning for a comprehensive modernization with incremental delivery to fast track your compliance-ready platform while setting you up for long-term success.

We use vertical slicing of complete user workflows rather than horizontal technology layers. This gives your team usable features faster and allows for immediate testing instead of waiting for everything to be finished.

Real Results, Not Just Promises: Proven Success in PBM Transformation

Our PBM client results speak for themselves:

• Coverage for 25+ million lives successfully migrated to a modern transparency platform
• 100K unique benefit plan types supported with simplified configuration
• 4-year ongoing engagement showcasing our sustained value and partnership
• 96% client referral rate, reflecting our client’s satisfaction and their successful outcomes

We move fast because the looming transparency deadline demands it. Our delivery model provides usable solutions quickly and real progress every sprint.

Are You Ready To Lead?

If your current systems can’t support full disclosure that’s on time, in real-time, and at scale, then it’s past time to get focused.

With only about 90 days until the deadline, what comes next is up to you.

Transparency mandates have permanently raised the bar, and the PBMs positioned to lead will be the ones that treat disclosure not as a burden but as a business model advantage.

Sponsors are taking a hard look at which PBMs offer full transparency. User-centric design, real-time analytics, and seamless data sharing will become expected parts of the process.

You don’t want to show up with a printed PDF when your competitors are providing automated transparency dashboards.

The PBMs That Win Will Be Transparent by Design

The PBMs that become market leaders in this moment will have platforms that automatically surface insights, seamlessly handle audit requests, and deliver real visibility into cost and value for plan sponsors.

That’s what transparency by design looks like.

At Praxent, we’ve built for that future. Let’s get your platform ready to compete in it.