How does a plan sponsor audit its pharmacy benefits if the pharmacy benefits manager (PBM) restricts access to data?  Why does the PBM contract limit a plan’s access to data and the right to conduct a meaningful audit?  How can a plan sponsor fulfill its fiduciary duty to its members without the data?  

These are questions that the Consolidated Appropriations Act of 2021 (CAA) seeks to resolve. Plan sponsors need to understand the CAA and demand access to the information and data.

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