TIER 2 · PBM DISCLOSURE · AUDIT WORKSHEET
Five Disclosures Your PBM Owes You Annually.
Most Plan Sponsors Receive One. The Worksheet Tracks All Five.
A 2-page printable worksheet PBS uses across 100s of PBM contract reviews annually. Free download. Sent to your inbox.
Three audit passes on your PBM's disclosure obligations
Five disclosures the PBM owes you annually
Track what you received against what's owed
Paste-ready inquiry record for the missing disclosures
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A complete audit framework you can run in half a day.
WHAT IS IN THE WORKSHEET
PASS 03
Build the Inquiry Record
The worksheet tracks what you actually received against what the contract and law require. A disclosure you never got is not a missing email; it is a compliance gap with your name on it.
PASS 01
Know the Five Disclosures
Your PBM owes you five disclosures annually: direct and indirect compensation, rebate aggregation, owned-affiliate transactions, formulary-decision rationale, and conflict-of-interest reporting. Most plan sponsors receive one, if any.
PASS 02
Track Received vs. Owed
The worksheet tracks what you actually received against what the contract and law require. A disclosure you never got is not a missing email; it is a compliance gap with your name on it.
ACTION PLAN
This Quarter's Action Plan
Run the three passes, document the disclosure gaps, send the inquiries, and require all five in the next contract. Disclosure you have to ask for repeatedly is disclosure designed not to happen.