Frost Health LawAlabama Attorney • Pharmacist • Healthcare Executive

PBM • Medicare Part D • Reimbursement • Contracting

CMS Proposes New Part D PBM Compensation and Disclosure Rules

CMS has proposed regulations governing Medicare Part D PBM compensation, reporting, price guarantees, and plan-sponsor oversight. The proposal implements provisions of the 2026 appropriations law, with contract requirements beginning in 2028. For pharmacy leaders, the practical questions concern reimbursement transparency and sponsor oversight. The implementing details remain proposed. The published notice sets December 15 at 5 p.m. Eastern Standard Time as the comment deadline.

By Toby C. “Chad” Frost • October 22, 2026
1 min read

What CMS proposed

CMS announced the proposal on October 16, 2026. It would implement the appropriations law’s Part D requirements for PBM compensation, reporting to sponsors and CMS, price-guarantee transparency, and disclosure of certain manufacturer agreements. This is federal proposed rulemaking implementing enacted legislation.1

The October 20 published rule would require covered sponsor agreements beginning with plan years on or after January 1, 2028. Proposed audit rights belong to Part D plan sponsors. They do not create an independent pharmacy right to audit a PBM.2

The practical next step

The published notice requires comments by December 15, 2026, at 5 p.m. Eastern Standard Time. The fact sheet instead describes a 60-day period after publication. Readers planning a submission should use the notice’s explicit deadline and recheck docket CMS-2026-2533 before filing.12

Chad’s analysis: Pharmacy leaders can use this comment period to document how reporting definitions and contractual incentives affect reimbursement and network relationships. Separate current contractual rights from possible future benefits of stronger sponsor oversight.

Source notes

  1. Ctrs. for Medicare & Medicaid Servs., Medicare Program; Implementation of Sections 6219, 6220, and 6224 of the Consolidated Appropriations Act, 2026 (CMS-4214-P), Fact Sheet, Background & Implementing Certain Provisions (Oct. 16, 2026).
  2. Medicare Program; Implementation of Sections 6219, 6220, and 6224 of the Consolidated Appropriations Act, 2026, 91 Fed. Reg. 66,408, 66,408, 66,433–34 (Oct. 20, 2026) (proposed 42 C.F.R. §§ 423.2808, 423.2818).