What Employers Should Actually Demand from PBM Transparency
Meet Lori Daugherty and hear her panel presentation at the SIIA 2026 National Conference, Phoenix, AZ
Everyone says they are transparent. The real question is whether they can prove it.
During the Self-Insurance Institute of America’s 2026 National Conference “Upend The Status Quo” session, RxLogic CEO Lori Daugherty will join other industry leaders to examine how employers can rethink longstanding benefit practices and move beyond opaque pharmacy benefit models. At the center of that discussion is a question the industry can no longer avoid. What separates organizations that claim transparency from those that can prove it?
Transparency has become one of the most widely used terms in pharmacy benefits but there is still no shared industry definition. One organization may use it to describe pass-through pricing. Another may point to a periodic report. An employer may receive more data than before and still lack the information needed to verify how claims were priced, rebates were handled or compensation was earned.
That distinction is becoming more important with The Consolidated Appropriations Act of 2026 establishing significant new federal requirements related to pharmacy benefit management services, including greater disclosure of pricing and compensation, rebate and other remuneration requirements, reporting obligations and enhanced audit rights. The Department of Labor has separately proposed additional requirements governing disclosures of PBM compensation and financial arrangements to fiduciaries of self-insured ERISA group health plans.
RxLogic provides the independent technology infrastructure needed to produce that evidence. Claims adjudication, rebate administration, manufacturer programs and financial workflows operate within a connected, configurable environment where activity can be tracked at the transaction level.
A Report Is Not the Same as Transparency
Reports remain important but true transparency begins before a report is generated. It exists within the rules, data and workflows that produce each result.
Employers should expect access to claim-level pricing information, rebate activity, direct and indirect compensation, contractual terms and the records needed to test whether agreed-upon arrangements were followed. They should also be able to determine who owns the data, how quickly it is available and whether an independent audit can verify it.
If an organization cannot reconstruct a transaction from the original claim through rebate and payment activity, transparency remains difficult to prove. Producing another summary after the fact does not resolve that limitation.
The RFP Must Test the Infrastructure
Pass-through pricing and rebate guarantees remain important, but they no longer provide a complete basis for evaluating a PBM or technology partner. Employers issuing an RFP should also ask:
- Can pricing decisions be traced to the rules applied at adjudication?
- Are rebate submissions, receipts, rejections and payments documented at the claim level?
- Can financial outcomes be reconciled to claims without relying on spreadsheets or disconnected systems?
- Does the platform preserve an audit trail when plan rules, formularies or programs change?
- Can the organization provide data in a usable format without delay or restriction?
These questions reveal whether transparency is part of the operating model or a reporting layer added after the work is complete.
The Next Generation Will Operate Differently
The next generation of pharmacy benefit organizations will not be distinguished by a “transparent” label – they will be distinguished by how their systems work.
Claims adjudication, rebate administration, manufacturer affordability programs and financial reporting can no longer function as isolated processes. When these activities are disconnected, employers face fragmented data, manual reconciliation and limited visibility into how financial results were produced.
RxLogic connects these functions through an independent, cloud-native platform. Configurable rules are applied in real time, while claim-level data and documented workflows give clients the visibility needed to evaluate performance. Because RxLogic operates as an independent technology and services platform and does not retain rebates, steer claims for its own economic benefit or monetize spread pricing, clients retain control over plan design, vendor relationships and program strategy.
Proof Will Define the Market
Over the next three to five years, the organizations that lead the market will be those that can substantiate their claims of transparency continuously. They will be able to show how each outcome was produced, provide complete data, support meaningful audits and adapt as federal requirements evolve. Employers don’t need another definition of transparency -- they need evidence and the infrastructure capable of producing it.
Connect with RxLogic to see how independent, configurable technology can provide the operational proof required for accountable pharmacy benefit management.
