Testimony on PBM Compensation and Fee Disclosure

This document is about testimony presented to the ERISA Advisory Council by William J. Kilberg of Gibson, Dunn & Crutcher LLP on whether mandatory disclosure requirements should be imposed on pharmacy benefit managers (PBMs) pursuant to section 408(b)(2) of ERISA. The testimony outlines the PBM business model, the PBM contracting process, and argues that imposing mandatory disclosure rules on PBMs would be counterproductive.