On February 3, 2026, President Trump signed the Consolidated Appropriations Act (CAA) into law. Among many provisions in the bill was historic, bipartisan reform of the pharmacy benefit manager (PBM) industry. It enshrined full transparency into federal law, dictated how employers, unions, and the government contract with PBMs, set in motion major changes to Medicare Part D, and gave Big Pharma a massive win with “delinking”.

At the time, lawmakers, interest groups, pundits, and the media celebrated the landmark reform.

Congressman Buddy Carter (R-GA) recognized the historic nature of the legislation, saying “I can proudly say that we have enacted the first major PBM reform in decades.”

Big Pharma’s trade group applauded “the broad, bipartisan coalition of lawmakers who came together to pass meaningful PBM reform. These reforms are a win for patients, pharmacists, providers and employers who have urged Washington to hold PBMs accountable.”

Former Speaker Newt Gingrich and former Governor Bobby Jindal noted that “Congress included significant pharmacy benefit manager (PBM) reforms in the 2026 spending package that strengthened transparency and rebate pass-through requirements…”

And the trade publication US Pharmacist remarked, “CAA 2026 represents the most consequential federal intervention in PBM regulation to date, establishing a transparent, auditable, service-based framework across the commercial market and Medicare Part D.”

With transparency and accountability requirements now federal law, attention has shifted from passage to implementation.

PBMs, health plans, employers, and federal agencies are now working through the complex operational and regulatory details needed to turn the legislation into practice. PBMs are committed to working with the Centers for Medicare & Medicaid Services (CMS) to ensure implementation reflects Congressional intent and achieves the law’s goals.

However, meaningful implementation takes time. Imposing additional or duplicative requirements, including those in a harmful pending Department of Labor rule, before the CAA is fully implemented and evaluated, will cause administrative, operational, and compliance costs to skyrocket, with those costs ultimately borne by patients, employers, and taxpayers.

PBMs are supporting efforts to carry out the law by engaging with policymakers, employers, and government agencies to help achieve its goals: greater transparency, stronger accountability, and continued access to affordable prescription drugs for patients.

Up next: Congress delivered the most significant PBM reform ever six months ago. Tomorrow, we take stock of what’s changed and what comes next.