Business Group Submits Comments on Potential PBM Transparency Reform

Business Group on Health urges Congress to remove civil monetary penalties from PBM reform to protect employer plan design flexibilities.

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November 12, 2025

Business Group on Health submitted comments to Congressional leadership supporting price transparency reforms while opposing civil monetary penalties and excise taxes that would undermine employer plan fiduciary authority and flexibility. The letter emphasizes the importance of preserving ERISA’s existing enforcement framework and maintaining employer control over plan design, vendor oversight and fiduciary delegation.

Business Group Submits Comments on Potential PBM Transparency Reform

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