Your PBM is about to tell you what it earns. We show you whether the claims agree.
Expose FI gives self-funded employers claim-by-claim visibility into what their pharmacy benefit pays, checked against a public federal drug-cost benchmark.
- Within benchmark
- Paid above benchmark
- Every claim, not a sample
- Public federal benchmark
- Built for HIPAA-regulated data
- Your data can stay in your environment
A new federal rule puts PBM pricing on a calendar
The Department of Labor finalized its PBM disclosure rule on October 29, 2026. It applies to large self-funded ERISA plans for plan years beginning on or after July 1, 2027. Here is what that calendar looks like for a plan sponsor.
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Oct 29, 2026
Rule finalized
The DOL issues its final PBM fee disclosure rule under ERISA.
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Now to mid-2027
Renewals before the rule
Contracts signed now are the moment to secure audit and claims-data rights.
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~90 days before renewal
First disclosure
For covered plan years, your PBM tells you in writing, in dollars, what it expects to earn.
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Every six months
Compensation reports
Your PBM reports what it actually earned from your plan.
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Once a year
Your audit right
Your plan can audit the PBM with an auditor it chooses.
The rule is not in force for today’s renewals, and a legal challenge is expected. Ask your benefits counsel how it applies to your plan.
Read the rule in plain EnglishThe rule makes PBMs report. It doesn’t make anyone check.
Disclosures are the PBM’s own numbers. Most mid-market plans will receive them without the staff or the data to test them. Expose FI is that check.
What your PBM will report
- What it expects to earn from your plan
- Spread by drug and pharmacy channel
- Steering to PBM-affiliated pharmacies
What Expose FI shows you
- What your plan paid on every claim
- How each claim compares to the federal benchmark
- The drugs and pharmacies driving the difference
How it works
One file in. A clear picture out. No system integration.
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Share your claims file
One pharmacy claims extract from your PBM or TPA, under a Data Use Agreement. No names or addresses.
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We check every claim
Each prescription is compared to the federal drug-cost benchmark in force on the day it was filled.
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See your numbers
A clear dollar figure, and the drugs and patterns driving it, walked through with your team.
What Expose FI does for your plan
Find overpayments
See where your plan paid more than a reasonable cost for prescriptions.
Protect your fiduciary role
Show your plan is actively monitoring what it pays, as federal rules now expect.
Negotiate from facts
Bring hard numbers to your PBM renewal and see what may be recoverable through your contract rights.
Who we work with
Self-funded employers
Plan sponsors with 100 or more participants who want to know what their pharmacy benefit really costs before the next renewal.
For employersBenefits consultants
Brokers and consultants whose clients will ask what to do with their PBM’s new reports. We sit behind your work, and you present the results.
For consultantsBuilt by partners who have been on every side of the claim
A hospital board veteran, a practicing physician, attorneys who fight for their clients, and a secure-data architect. Technology and security partner: Archia.
Meet the partners-
Jim Hake
- Dr. Kelvin Walls
- Jonathan Buschmann
- Erik Klinkenborg
- Gharib Gharibi
Start with a free Expose FI Snapshot
We analyze your plan’s pharmacy claims and show you the savings opportunity. No cost, no obligation, and your data never has to leave your control.