Pharmacy and PBM. Know where every drug dollar goes.

Your pharmacy benefit is often the hardest part of your plan to see into. Ethos Benefits reviews it from the contract up: how your PBM is paid, where spread pricing and rebates go, and what your plan pays per drug. Then your committee decides whether to renegotiate, carve the PBM out or replace it.

What you get.

Your pharmacy benefit manager may be owned by the same company that sells you the plan, and its contract decides what it keeps. Many employers have never seen what their plan actually pays per prescription.

  1. PBM contract reviewA clause-by-clause review of your PBM contract against a fiduciary checklist, with each gap ranked by severity and the replacement language to negotiate.
  2. Pharmacy spend analysisYour top drugs, specialty spend and cost per member per month, read from your claims data rather than a carrier summary.
  3. PBM marketing, when it's neededIf the contract can't be fixed, a request for proposal to PBMs with terms written for your plan, and the bids compared side by side for your committee.
  4. High-cost drug reviewFor the most expensive prescriptions, a clinical review and options such as manufacturer assistance programs and international sourcing where appropriate, without changing the medication.
  5. Quarterly monitoringPharmacy results reviewed with your committee every quarter, against the targets in your Fiduciary Framework™.

How your PBM gets paid.

A pharmacy benefit manager sits between your plan, the pharmacies and the drug makers. Depending on its contract, it can earn money in several ways, and some of them are hard to see:

  • Spread pricing: charging your plan more for a prescription than it pays the pharmacy, and keeping the difference.
  • Rebates: payments from drug makers that may be passed through to your plan, kept by the PBM, or split, depending on how the contract defines them.
  • Fees: administrative and other fees, some of which are not on your invoice.

When the PBM is owned by your carrier, the same company sets the drug prices and sells you the plan. That is worth knowing before you renew.

What we check in the contract.

  1. Definitions: how “brand,” “generic” and “specialty” are defined. Pricing guarantees depend on them.
  2. Rebates: what counts as a rebate, and what share reaches your plan.
  3. Spread: whether the PBM may keep the difference between what your plan pays and what the pharmacy is paid.
  4. Audit rights: whether your plan can audit the PBM, how often, and with whose auditor.
  5. Data: whether your plan can get its own claims data, which federal law now protects through the gag clause ban.
  6. Specialty pharmacy: whether specialty prescriptions are steered to a pharmacy the PBM owns.
  7. Termination: how and when your plan can leave, and what it costs.

How we run a PBM RFP.

When a PBM needs to be replaced, it goes through Ethos Fiduciary Procurement:

  1. Requirements for your plan’s pharmacy benefit, agreed with your committee.
  2. A standardized questionnaire, covering 43 questions across 11 topic areas, from pricing and rebates to clinical programs, data and service.
  3. Contract terms, with 29 terms each bidder must accept, reject or modify.
  4. Weighted scoring, blending the questionnaire (60%) and the contract terms (40%).
  5. Finalists, negotiation and a redlined contract, then implementation and quarterly monitoring.

New PBM rules.

Federal law signed in February 2026 adds reporting, rebate pass-through and audit requirements for pharmacy benefit managers. They apply to PBM contracts for plan years beginning on or after August 3, 2028, which is January 1, 2029 for a calendar-year plan. Read what the law requires. A PBM contract signed now runs into those years, so Ethos reviews new contracts against the obligations that are coming, not just the ones in force today.

What changed for Kalos.

Kalos Services, an HVAC and construction company in Central Florida, came to Ethos on a fully insured plan. Its PBM was owned by its carrier. After moving to a fiduciary PBM, with manufacturer assistance programs and international sourcing where appropriate, Kalos’s pharmacy cost fell to $17 per member per month, a 70% decrease.

One employee’s specialty medication cost $7,100 every two weeks. After a clinical review confirmed it was medically necessary, the same medication was sourced through international mail order for $3,500 every two weeks.

Figures as published in the Kalos Services case study, with Kalos’s permission.

How it fits your fiduciary duty.

Paying only reasonable plan expenses is part of the duty of loyalty, and monitoring what vendors are paid is part of prudence. A documented PBM review is how your committee shows it did both. Read what the duty requires.

Part of your Fiduciary Framework™.

Every Ethos service reports to your benefits committee. The work is reviewed at your quarterly committee meeting, each decision is recorded with the reasoning behind it, and the record lives in your Ethos Fiduciary OS. That is what lets your committee show the plan was run prudently.

See the Fiduciary Framework™ · How fiduciary governance works

Questions employers ask about this.

What is PBM spread pricing?

Spread pricing is when a PBM charges your plan more for a prescription than it pays the pharmacy and keeps the difference. Whether your contract allows it, and how pricing guarantees are measured, is one of the first things to check in a PBM review.

Do we have to change PBMs?

No. Sometimes the contract can be renegotiated. When it can't, the PBM can be marketed and your committee decides with the options side by side. Either way, the decision and the reasoning behind it are recorded.

Can a fully insured plan change its PBM?

Usually not on its own. On a fully insured plan, pharmacy is generally part of the carrier's package. Separating pharmacy from medical, called a carve-out, is usually done on a self-funded or level-funded plan, which is a larger decision your committee would weigh with the full numbers.

Will employees have to switch medications?

Not as a rule. In the Kalos Services example below, an employee kept the same specialty medication while the plan paid less for it. Any formulary change is reviewed before it happens and explained to employees.

See what your plan is really costing you.

A Strategic Analysis starts with your plan documents and your broker agreement, then shows you what your plan costs, where the risk sits, and what a committee would decide with the full picture.