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Payers, Providers, and Patients – Oh My!: More Changes to Section 1557 Nondiscrimination Rules

Client Alert | 1 min read | 11.30.22

In this episode, hosts Joe Records and Payal Nanavati talk to Michelle Chipetine and Stacie Heller about recent developments regarding the nondiscrimination requirements of Section 1557 of the Affordable Care Act, including new rules proposed by the Biden Administration and litigation around the issue of discrimination on the basis of sex.

Payers, Providers, and Patients – Oh My! is Crowell & Moring’s health care podcast, discussing legal and regulatory issues that affect health care entities’ in-house counsel, executives, and investors.

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Insights

Client Alert | 7 min read | 11.02.26

DOL Finalizes PBM Fee Disclosure Requirements

On October 29, 2026, the U.S. Department of Labor’s (DOL) Employee Benefits Security Administration (EBSA) issued a 350-page final rule requiring providers of pharmacy benefit management services and their affiliated brokers and consultants to disclose fees and compensation received to fiduciaries of covered large, self-insured ERISA group health plans. According to DOL’s accompanying fact sheet, the disclosures will give employers more visibility into the payments PBMs may receive from various sources and help fiduciaries evaluate and monitor arrangements over time. ...