Growing Public Attention Raises the Importance of PBM Procurement

Selecting a Pharmacy Benefit Manager (PBM) has always been an important decision. PBMs influence prescription drug access, pharmacy networks, clinical programs, specialty pharmacy strategies, and a substantial component of healthcare spending.

What is changing is the environment surrounding that decision.

PBMs are receiving sustained attention from policymakers, regulators, employers, pharmacies, patients, and other healthcare stakeholders. Federal activity has included proposed PBM fee-disclosure requirements from the U.S. Department of Labor and Federal Trade Commission actions involving PBM business practices. States continue developing their own approaches to PBM procurement, oversight, and transparency. Pennsylvania, for example, began requiring annual PBM transparency reports in 2026 covering areas including rebates, administrative fees, retained rebates, and reimbursements involving affiliated entities.

The merits and long-term effects of individual policy proposals will continue to be debated. Procurement teams do not need to predict where those debates will ultimately lead to recognize a more immediate consequence.

When an important vendor relationship receives greater attention, the process used to select that vendor becomes more important as well.

For organizations purchasing PBM services, this creates an opportunity to think about transparency more broadly. Transparency is not only about understanding what happens after a PBM contract begins. It can also include understanding which vendors were considered, what information was compared, what tradeoffs were identified, and why a particular solution was ultimately selected.

The question is no longer only whether an organization made a good decision.

Increasingly, it also matters whether the organization can clearly explain how it made that decision.

PBM Decisions Are Receiving More Attention

The current attention surrounding PBMs did not emerge from a single issue.

Prescription drug affordability remains a significant concern for employers and patients. Specialty medications continue creating new financial and clinical considerations. Policymakers have examined PBM compensation, rebates, pharmacy reimbursement, ownership relationships, network practices, and other aspects of the industry.

Recent federal activity illustrates the breadth of that attention. In January 2026, the Department of Labor proposed rules that would require PBMs serving certain employer-sponsored self-insured health plans to provide detailed information about compensation and financial arrangements to plan fiduciaries. The Department subsequently extended its comment period following new PBM-related statutory provisions enacted through the Consolidated Appropriations Act, 2026.

States are also developing different reporting and oversight requirements. Pennsylvania’s Pharmacy Benefit Reform Act, for example, now requires registered PBMs within its scope to submit annual network adequacy and transparency reports. The first transparency reports were due July 1, 2026.

These developments should not be interpreted as evidence that every criticism of PBMs is justified or that every policy proposal will improve pharmacy benefits. PBMs operate within a complicated healthcare system and perform functions that employers and health plans continue to need.

What these developments demonstrate is much simpler: PBM relationships are being examined more closely.

That changes the environment in which procurement decisions are made.

EXECUTIVE PERSPECTIVE
Greater scrutiny of an industry naturally increases the value of being able to explain how important purchasing decisions were made.

Transparency After Selection Is Only Part of the Question

Much of the PBM transparency discussion understandably focuses on the contractual and operational relationship between a PBM and its client.

Organizations may want greater visibility into pricing, rebates, fees, pharmacy reimbursements, clinical programs, specialty pharmacy arrangements, guarantees, and other elements of PBM performance. Current policy activity reflects many of those concerns. The Department of Labor’s proposed disclosure rule, for example, focuses on information intended to help covered plan fiduciaries evaluate PBM compensation and financial arrangements.

That is one form of transparency.

Procurement transparency addresses a different question.

How did the organization decide which PBM relationship to enter in the first place?

A procurement process may be rigorous while remaining difficult to reconstruct later. Hundreds of questions can be answered. Multiple spreadsheets can be analyzed. Consultants and internal teams can spend months evaluating proposals. Yet if information was presented differently across vendors, decision-makers may still find it difficult to communicate the most meaningful differences that ultimately drove the decision.

Greater procurement transparency does not require making confidential proposals public or eliminating professional judgment.

It means creating a process in which the reasoning behind the decision is easier to understand.

That can include clearer qualification criteria, more consistent vendor information, documented evaluation priorities, meaningful comparisons, and an understandable record of the tradeoffs considered during selection.

Transparency after selection helps an organization understand the relationship it purchased.

Transparency during selection helps it understand why it purchased that relationship.

A Good Decision Should Also Be Explainable

Procurement professionals regularly make decisions involving imperfect information and competing priorities.

The PBM offering with the lowest projected cost may not provide the preferred clinical model. The broadest pharmacy network may involve different economic tradeoffs. A particular specialty pharmacy strategy may align strongly with one organization and poorly with another. Service models, implementation capabilities, guarantees, reporting, member experience, and contractual provisions can all influence the final recommendation.

There may be no universally correct answer.

That makes the quality of the decision-making process especially important.

An organization should ideally be able to explain several things after completing a procurement:

• Which qualified vendors were considered?
• Why were those vendors included?
• What criteria mattered most?
• What meaningful differences emerged?
• What tradeoffs were evaluated?
• Why did the selected PBM best fit the organization’s priorities?

This is not about creating documentation merely to protect against criticism. Nor does it imply a particular legal standard.

It is about organizational decision quality.

A procurement process that produces an understandable rationale gives executives, governing bodies, consultants, and procurement teams greater confidence in the result. It also creates institutional knowledge that can inform contract management and the next procurement cycle.

A good decision should survive more than the moment in which it was made.

It should remain understandable later.

EXECUTIVE PERSPECTIVE
Transparency should not begin after a vendor is selected. The selection process itself should be understandable.

Competition Strengthens the Procurement Record

A strong evaluation process depends partly on what happens before formal evaluation begins.

Vendors first need an opportunity to be considered.

Organizations cannot evaluate every PBM in the market, nor should they attempt to. Vendor qualification serves an important purpose by identifying organizations capable of meeting a requestor’s requirements. Consultants also provide valuable market knowledge that helps clients determine which vendors merit consideration.

But there is an important difference between qualification and familiarity.

Established PBMs naturally benefit from broad market recognition, extensive relationships, and long operating histories. Regional PBMs, emerging models, and less familiar organizations may have relevant capabilities but lower visibility during the earliest stages of procurement.

That matters because the strength of a procurement is influenced by the alternatives available to the requestor.

Competition does not require inviting every possible vendor into every Request for Proposal (RFP). It requires giving requestors sufficient visibility to make informed choices about which qualified vendors deserve deeper evaluation.

A broader understanding of the available market can strengthen the eventual procurement record. Leadership can understand not only why the selected PBM performed well against finalists, but why those finalists represented appropriate alternatives in the first place.

Vendor evaluation determines which option is preferred.

Vendor discovery helps determine whether the right options were available to compare.

Standardization Makes Comparison Easier to Demonstrate

Transparency becomes more difficult when every vendor describes similar capabilities differently.

This is a familiar problem in complex procurement.

One PBM may provide detailed narrative explanations. Another may rely heavily on spreadsheets and exhibits. Definitions can vary. Financial assumptions may require normalization. Similar clinical programs may be organized under different categories or described using different terminology.

Experienced consultants and procurement professionals know how to work through these differences. But the administrative effort required to create comparable information can obscure something more important: the actual differences between the vendors.

Standardization helps separate those two problems.

When foundational vendor information is organized consistently, the procurement team can spend less time determining whether two answers are comparable and more time evaluating what the answers mean.

That also improves explainability.

Decision-makers can see where vendors align, where they differ, and which differences mattered to the organization. Supporting information can still provide depth, and custom questions can still address organization-specific requirements, but the underlying comparison begins from a more consistent foundation.

Standardization should not make every vendor look the same.

Its purpose is to make meaningful differences easier to see.

PfRs Can Expand Transparency Before the RFP Begins

Proposal for Requestors (PfRs) extend that principle to an earlier stage of procurement.

Instead of waiting for a requestor to issue an RFP before vendor information is assembled, PfRs allow PBMs to maintain structured, standardized, reusable proposals within a secure marketplace accessible to qualified requestors.

That changes when transparency becomes available.

A requestor or consultant can begin researching the PBM landscape before determining which vendors should enter a formal procurement. Foundational information can be reviewed within a common structure, allowing qualified alternatives to become visible earlier.

The reusable nature of PfRs is particularly important.

PBMs routinely provide similar foundational information across multiple procurement opportunities: capabilities, service models, clinical programs, networks, implementation approaches, organizational information, and other characteristics of their offerings. Requiring that information to be recreated for every procurement consumes resources on both sides.

A reusable proposal allows the PBM to maintain that information as its offering evolves. Requestors and consultants can then begin their research with information that already exists rather than starting every vendor relationship with a new document request.

Procurement-specific work remains necessary.

Organizations still need custom financial analysis, organization-specific questions, due diligence, negotiations, legal review, and other evaluation activities appropriate to their circumstances. Consultants still provide strategy, market expertise, analysis, negotiation support, and implementation guidance.

PfRs improve the information available before those activities begin.

That can create a clearer progression from vendor discovery to qualification to evaluation and ultimately selection. It also provides requestors with greater visibility into alternatives before a bid list is finalized.

In an environment where organizations increasingly value transparency, that earlier visibility may become as important as transparency within the eventual contract.

Better Procurement Is Valuable Regardless of What Regulation Comes Next

The PBM policy environment will continue changing.

Some proposals will become requirements. Others will change substantially or never take effect. Federal and state approaches may differ. Courts, regulators, employers, PBMs, pharmacies, consultants, and other stakeholders will continue influencing how the industry develops.

Procurement teams do not need to predict the outcome.

The case for better procurement exists independently.

An organization benefits from understanding the available vendor landscape. It benefits from meaningful competition among qualified alternatives. It benefits from comparable information. It benefits from documenting important tradeoffs. And it benefits from being able to explain why its eventual decision made sense.

Those characteristics become more valuable when public attention increases, but they do not depend on public attention to be worthwhile.

This is why the current PBM discussion presents an opportunity rather than simply another compliance challenge.

Organizations can respond to greater scrutiny by waiting for new requirements and adjusting procurement as necessary. Or they can use the changing environment as a reason to examine whether their existing procurement processes already provide the transparency, competition, comparability, and decision clarity they want.

The strongest procurement process is not necessarily the one with the most documentation.

It is the one that leaves the organization understanding its options, its tradeoffs, and the reasoning behind its decision.

Public attention may be increasing the importance of that standard.

Good procurement made it valuable all along.

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Rapid Request is building procurement around Proposal for Requestors (PfRs), giving qualified requestors and consultants access to structured, reusable vendor information earlier so they can understand available options and begin formal procurement from a stronger foundation.