Rivera examines why PBM legislation is accelerating the need for continuous oversight

Mar 11, 2026

In Rivera’s latest issue brief on PBM legislation, we outline why reform is raising the bar for oversight without solving the oversight problem itself.

New federal and state requirements are increasing scrutiny of PBMs and expanding what they are expected to disclose. What they do not do is confirm that PBMs are applying contract terms, benefit rules, and payment logic correctly in practice.

As those obligations grow, traditional oversight approaches are proving less sufficient. Rivera’s view is that continuous PBM oversight is becoming a necessary discipline for plans that need independent verification of PBM performance, earlier visibility into issues, and stronger accountability between what was agreed to and what is actually happening.

Read the full brief → Reform does not enforce itself

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