Recent federal actions signal a renewed focus on prescription drug pricing transparency and cost containment. While each development addresses a different part of the pharmacy ecosystem, taken together they reflect a broader shift toward increased visibility, alternative purchasing models and closer scrutiny of pharmacy benefit manager (PBM) practices.
Each of these events will have a significant impact on the future of pharmacy benefits.
TrumpRx Launches: A New Direct-to-Consumer Pricing Channel
On February 5, 2026, the federal government launched TrumpRx, a direct-to-consumer prescription drug pricing website intended to help patients find discounted prices on select high-cost medications. The site does not sell drugs directly; instead, it typically routes patients to manufacturer purchasing channels or digital coupons that allow them to pay cash rather than use insurance.
At launch, TrumpRx includes roughly 40 branded drugs from participating manufacturers, with pricing benchmarked to the lowest prices paid in other developed countries under a most-favored-nation (MFN) pricing approach. While some of these medications have generic alternatives available at lower prices, others reflect materially lower brand-name pricing compared to traditional point-of-sale costs.
Importantly, TrumpRx operates outside traditional employer-sponsored health plans and PBM benefit structures. Purchases made through the platform are structured as cash-pay transactions and are generally not submitted for reimbursement to insurance or federal programs. As a result, these purchases may not apply toward deductibles or out-of-pocket maximums unless plan rules or regulatory requirements change.
For medications that are excluded from coverage or carry high out-of-pocket costs, employees may already be shopping across multiple cash-pay and discount options, such as GoodRx, Costco or the Mark Cuban Cost Plus Drug Company. In that context, TrumpRx functions as an additional pricing reference point rather than a replacement for employer-sponsored pharmacy benefits.
While TrumpRx currently operates outside traditional PBM structures, recent enforcement activity suggests that the boundaries between these models may continue to evolve. The Federal Trade Commission (FTC) settlement with Express Scripts offers an early indication of that direction.
FTC Settlement with Express Scripts: Signals a Shift Toward Net Pricing
On February 4, 2026, the FTC announced a settlement with Express Scripts, one of the nation’s largest PBMs, resolving allegations tied to rebate-driven practices that contributed to inflated insulin list prices and higher out-of-pocket costs for patients.
Under the agreement, Express Scripts did not admit wrongdoing and will not pay a financial penalty. Instead, the settlement requires a series of forward-looking changes focused on transparency, incentive alignment and greater reliance on net prices rather than list prices.
These commitments include ending formulary preference for higher list-price drugs when lower-cost equivalents are available; offering options that base member cost-sharing on net prices; delinking manufacturer fees from list prices; expanding plan sponsor transparency (including drug-level reporting and broker disclosure); and shifting pharmacy reimbursement toward more transparent models. The settlement also anticipates access to direct-to-consumer channels such as TrumpRx, where permitted and subject to legal and regulatory requirements.
Once finalized, the consent order will carry the force of law and include defined implementation timelines and compliance monitoring. While the settlement applies only to Express Scripts, it reinforces broader regulatory momentum toward PBM models that emphasize clearer pricing structures and reduced reliance on opaque rebate-driven incentives.
CAA of 2026: PBM Reform and Expanding Transparency Expectations
The Consolidated Appropriations Act (CAA) of 2026 includes meaningful PBM reforms focused primarily on Medicare Part D. These provisions establish federal standards that signal the direction of PBM oversight and transparency more broadly, including requirements that delink PBM compensation from drug list prices (similar to the FTC settlement with Express Scripts), require full rebate pass-through to Medicare Part D plan sponsors, expand PBM reporting and audit authority and reinforce any-willing-pharmacy protections.
In parallel, federal agencies are advancing complementary transparency initiatives. The Centers for Medicare and Medicaid Services has finalized additional Hospital Price Transparency updates for 2026, and the U.S. Department of Labor has proposed new ERISA rules that would require PBMs to disclose detailed fee and compensation information directly to employer plan fiduciaries, along with expanded audit rights.
Taken together, these developments reflect rising expectations that plan sponsors understand how pharmacy dollars flow, how incentives are structured, and how pricing decisions affect both total cost and employee out-of-pocket exposure.
Work with Rx Solutions
As pharmacy pricing models, transparency requirements and regulatory expectations continue to evolve, employers are increasingly being asked to navigate this complexity across purchasing channels, PBM arrangements and fiduciary obligations. NFP’s Rx Solutions works alongside employers to help bring structure and clarity to this environment through independent oversight, analytics and ongoing pharmacy governance.
