The Consolidated Appropriations Act made a quiet but significant change: plan sponsors now have an affirmative obligation to understand what they are paying their service providers, and to be able to show that those fees are reasonable.
For medical benefits, that has always been relatively tractable. For pharmacy, it has not. Traditional PBM contracts are structured in ways that make the true cost genuinely difficult to determine, even for a sponsor acting in good faith with a competent broker.
The practical test is simple. Can you produce, from your own contract and reporting, the total amount your PBM earned from your plan last year? If the answer requires an assumption, an estimate, or a phone call, the disclosure is not adequate.
A fully disclosed contract answers that question on one line. That is the whole point of the structure: not that the fee is low, but that it is knowable.