Testimony of National Coordinating Committee for Multiemployer Plans

This document is the testimony of the National Coordinating Committee for Multiemployer Plans (NCCMP) to the ERISA Advisory Council, emphasizing the need for increased transparency in PBM compensation and fees to allow multiemployer plan fiduciaries to properly fulfill their duties to plan participants. It provides background on the PBM market, the various revenue streams of PBMs, the importance of formulary decisions, and the limitations of current PBM contract and audit practices. The testimony also addresses the current disclosure requirements under the Affordable Care Act and state laws, and concludes that additional federal-level regulation is needed to ensure adequate disclosure for ERISA plan sponsors.