Michael Dowell Reviews New PBM Reform Reshaping Pharmacy Reimbursement

Hinshaw partner Michael Dowell has authored a new column in the April 2026 edition of U.S. Pharmacist, which analyzes the Consolidated Appropriations Act (CAA), 2026—one of the most significant pieces of federal legislation to reshape pharmacy benefit manager (PBM) regulation in the United States.

Key Highlights

Michael’s article breaks down how the CAA fundamentally reshapes the PBM landscape—bringing unprecedented transparency, tighter fiduciary scrutiny, and a decisive shift away from rebate-driven economics. Key topics addressed include:

• • A new federal framework governing PBM transparency, compensation, and reporting across commercial plans and Medicare Part D
  • Expanded PBM reporting requirements and enhanced audit rights for plan fiduciaries
  • Tough bona fide service fee standards aimed at severing ties between PBM revenue, drug prices, and utilization
  • The requirement that PBMs pass through 100 percent of rebates and price concessions to plan sponsors
  • Practical implementation timelines, with major changes taking effect in the 2028–2029 plan years
  • The ripple effects on PBM business models, ERISA fiduciary risk, and pharmacy reimbursement
  • Open questions around state law preemption and emerging litigation risks

• • U.S. Pharmacist: “PBM Reform Reshaping Pharmacy Reimbursement” (April, 15 2026)