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Employer Benefits IQ

PBM Contract IQ™

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Upload your PBM agreement for an employer-focused review of pricing, rebates, specialty terms, audit rights, data access, and contract protections.

AI-Assisted™
AI model & data: August 2026

Pharmacy action path

Move from contract findings to pharmacy strategy

Use the contract review to identify the protections, data requests, and vendor questions that deserve attention first.

Save progress in Benefits IQ
  1. 1

    Review PBM contract protections

    Identify pricing, rebate, audit, specialty, and data-access terms that need follow-up.

    Review contract
  2. 2

    Compare PBM options

    Use a consistent employer-first lens when evaluating alternatives or preparing an RFP.

    Compare PBMs
  3. 3

    Add findings to your action plan

    Keep the highest-priority pharmacy decisions connected to your broader benefits strategy.

    Open action plan

Your action plan ranks opportunities by impact and urgency as you complete tools.

View Benefits IQ action plan

Do not upload documents containing PHI, claimant information, or confidential materials without authorization.

Stop-loss documents can contain individually identifiable information in laser schedules, underwriting disclosures, or claimant-related exhibits — even when described as plan-level documents. Before uploading, confirm you are authorized to share the document with a third-party AI analysis service under any applicable confidentiality agreement. Do not include claimant names, Social Security numbers, member IDs, claim-level detail, or any other protected health information (PHI).

✓ Appropriate to upload (de-identified): the policy, schedule of benefits, binding proposal, endorsements, laser schedules with claimant information removed, premium and attachment-point exhibits, and renewal amendments.

Your document is transmitted over HTTPS to OpenAI's API for analysis. EmployerBenefitsIQ does not retain the uploaded file after processing. OpenAI's applicable API data-handling terms apply. View our data handling policy →

1

Add the contract documents

Include the master agreement plus pricing, rebate, specialty, and amendment exhibits when available. The tool reviews them together.

2

Add context (optional)

These details help prioritize findings. The tool will not invent missing contract terms.

3

Run the review

You'll receive a 0–100 contract score, 15-category scorecard, prioritized findings, missing protections, negotiation priorities, and due-diligence questions.

Uploaded documents are deleted immediately after processing and are not used to train AI models. Document security policy

What the tool reviews

Headline guarantees can look competitive while definitions, exclusions, affiliate compensation, specialty restrictions, audit limitations, or termination language shift economics back toward the PBM.

Pass-through vs. spread pricing
Rebate and manufacturer revenue definitions
Specialty pharmacy economics
Audit and verification rights
Claims data ownership and portability
Formulary and clinical control
Pricing guarantee exclusions
Fees and affiliate compensation
Auto-renewal and termination deadlines
CAA, RxDC, gag-clause and fiduciary support
Performance guarantees
Liability, security and transition terms

Frequently Asked Questions

What should I look for in a PBM contract?

Key PBM contract provisions to review include: (1) pricing basis — how ingredient costs are calculated and what benchmarks apply for retail, mail, and specialty drugs; (2) rebate pass-through — what manufacturer-derived compensation is included in the definition, what the plan actually receives, and how it is verified; (3) spread pricing — whether the PBM can charge more than it pays pharmacies; (4) audit rights — the employer's right to independently verify pricing and rebate compliance; (5) data access — the employer's right to receive claims-level data; (6) termination provisions — notice period and data portability on termination. Note: AWP discount guarantees are a starting point, but net plan cost depends on ingredient-cost methodology, claims mix, channel, exclusions, rebates, and administrative fees — not headline discounts alone.

What is spread pricing in a PBM contract?

Spread pricing occurs when a PBM charges the employer more for a drug than it reimburses the pharmacy, keeping the difference as profit. For example, the PBM might reimburse a pharmacy $10 for a generic drug but charge the employer $15 — keeping $5 as spread. Pass-through or transparent pricing contracts eliminate spread by requiring the PBM to charge the employer exactly what it pays the pharmacy, plus a disclosed administrative fee.

What audit rights should an employer have in a PBM contract?

Employers should negotiate: (1) the right to audit PBM claims data and pricing at least annually; (2) access to actual acquisition cost data for drugs dispensed; (3) the right to use an independent auditor of the employer's choosing; (4) a reasonable audit window (at least 24 months of historical data); (5) the right to recover overcharges identified in an audit; and (6) no restrictions on sharing audit findings with advisors or consultants.

What data access rights should be in a PBM contract?

Employers should require: (1) access to complete, claims-level data including NDC codes, days supply, and actual drug costs; (2) data in a standard format (NCPDP or equivalent) that can be analyzed independently; (3) the right to share data with the employer's TPA, consultant, and analytics vendors; (4) data delivery within 30 days of request; and (5) data portability on contract termination — the right to receive a complete historical data extract.

How often should employers renegotiate or rebid their PBM contract?

Employers should formally review PBM contract terms every 2–3 years and conduct a full market RFP every 3–5 years. The PBM market changes rapidly — new transparent PBM models, improved pricing benchmarks, and evolving specialty drug strategies mean that contracts signed 3+ years ago may be significantly below market. PBM Contract IQ™ can identify specific provisions to renegotiate at your next renewal without a full rebid.

Is my PBM contract confidential — can I upload it here?

PBM contracts often contain confidentiality provisions that restrict disclosure to third parties, even without PHI. Before uploading, confirm that sharing the document with an AI analysis service is permitted under any applicable confidentiality agreement. An authorized representative of your organization should make that determination. Documents uploaded here are processed in memory and sent to OpenAI's API for analysis; they are not stored on our servers after the review is complete.

What PBM-related regulations apply to self-funded employers?

Several regulatory frameworks apply, but their status differs. The 2021 Consolidated Appropriations Act (CAA) and its 2026 amendments include enacted PBM transparency and compensation-disclosure requirements that apply to self-funded ERISA plans. The Department of Labor's January 2026 PBM fee-disclosure proposal remained a proposed rule as of early 2026 — not yet a legal requirement. RxDC reporting requirements apply under the applicable CMS framework. This tool flags provisions relevant to enacted requirements and distinguishes them from proposed rules and best-practice recommendations. Always confirm current regulatory status with qualified ERISA counsel.

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