Kaplan will share his views of PBM rule change efforts March 24 in Indianapolis, at a Prescription Drug Working Group session at the National Association of Insurance Commissioners' spring national meeting.

The working group has already put Kaplan's slidedeck in a meeting packet on its section of the NAIC's website.

Kaplan contends that PBMs do provide value, by performing efforts such as encouraging use of generic drugs; developing "formularies," or lists of covered drugs, that drive down costs; and providing support services that may make life easier for patients and keep some patients out of the hospital.

But the pharmaceutical industry is spending about $300 million per year on lobbying, and PBMs are now generating revenue through at least 11 different mechanisms, ranging from transaction fees to drug sales data sharing fees to marketing fees disguised as patient education services fees, Kaplan says.

Related: Federal pharmacy benefit manager regulation may be inevitable, but will push drug prices higher

Now, Kaplan says, PBMs are adding yet another stream of revenue, by acquiring generic drug manufacturers and getting into drug production.

Kaplan is not categorically rejecting the value of new PBMs' efforts to improve the situation by increasing price transparency.

But, at this point, as far as Kaplan can tell, in typical cases, there is "no such thing as pure transparency," and "no evidence yet that transparent deals producer lower costs on a [per member per month] basis."

Kaplan is cooler toward any willing provider rules for pharmacy networks.

"Deals based on AWP are inflationary," he says.

He thinks a better approach is to make sure that PBM incentives are tied to successful efforts to contain price increases.

He does want to see more drug price and PBM impact transparency. He also wants to see rules that require PBMs to pass 100% of any price rebates they negotiate on to the employer plan sponsors or participants.

"Ensure clients have reasonable audit rights," Kaplan adds.

Employers should have access to manufacturer rebate contracting terms, with disclosure of all manufacturer revenue sources, subject to a confidentiality agreement, he says.