YOUR PHARMACY PLAN IS LIKELY OVERPAYING
Glass River Analytics provides independent fiduciary audits of pharmacy benefit management arrangements for self-insured employers. No carrier relationships. No conflicts of interest. Just your data, analyzed independently.
Most self-insured employers have never independently reviewed their PBM contract.
If your company self-insures its health plan, you pay pharmacy claims directly. Your pharmacy benefit manager (PBM) processes those claims, negotiates drug prices, and administers your formulary.
Under ERISA and the Consolidated Appropriations Act (CAA) 2026, plan fiduciaries have a legal obligation to review and document whether their PBM arrangements are serving the best interests of plan participants. That obligation now has penalties attached: up to $10,000 per day per violation under DOL enforcement authority.
In many PBM contracts, the price charged to your plan is higher than the price the PBM actually pays the pharmacy. The difference is kept by the PBM. It never appears on an invoice. It is called spread pricing, and it costs self-insured plans hundreds of thousands of dollars per year in the aggregate.
Glass River Analytics exists to help plan sponsors understand what their PBM is actually doing with their money, and to document that understanding in a form that satisfies their fiduciary duty.
An independent audit, from your data to your report.
Step 1:We Start With Your Data
We request your plan's claims data and your current PBM contract. We do not need individual employee health information. We work from aggregate and de-identified plan data that your PBM or TPA can provide directly.
Step 2: Independent Benchmarking
We compare your plan's actual drug costs against NADAC, the National Average Drug Acquisition Cost maintained by the federal government. We also review your rebate pass-through terms, formulary construction, and specialty drug handling.
Step 3: You Receive a Written Report
Our report documents exactly what we found: where your plan is paying competitively, where spread exists, and what your options are. You own the report and can use it for ERISA compliance documentation, contract renegotiation, or RFP preparation.
The CAA 2026 compliance window is open. Most plans are not ready.
The Consolidated Appropriations Act requires self-insured plan fiduciaries to obtain and review detailed drug cost data from their PBMs, including spread pricing disclosures, rebate retention figures, and formulary rationale. The effective compliance deadline for most provisions is August 2028.
That sounds distant. It is not. PBM contracts run in multi-year cycles. Data requests require lead time. And the analysis itself takes weeks to complete properly.
Plan sponsors who begin the process now will have documented compliance before enforcement activity accelerates. Those who wait will be scrambling alongside everyone else in 2027.
Ready to find out what your plan is actually paying?
We work with self-insured employers with 150 to 1,500 plan participants. If your company self-insures and has never had an independent PBM review, that conversation starts with a 30-minute call.