The PBM Fiduciary Audit

One engagement. One question: is your plan paying what it should be paying?

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What the audit covers

Every Glass River audit covers four core areas of your PBM arrangement:

  • We benchmark your plan's actual drug reimbursement rates against NADAC for your top drug categories, identifying where your PBM is retaining margin that should stay in your plan.

  • We review your contract terms and actual rebate data to determine what percentage of collected rebates are being passed through to your plan versus retained by the PBM.

  • We examine how your formulary is constructed and whether specialty drug management is aligned with your plan's cost objectives.

  • We review your pharmacy network reimbursement structure and key contractual provisions that affect your plan's cost exposure.

At the end of every engagement, you receive a written audit report that includes:

1

A plain-language executive summary written for HR leadership and C-suite stakeholders, not just benefits specialists.

2

A claim-level spread pricing analysis showing where your plan is paying above market and by how much, expressed in both per-claim and annualized terms.

3

A rebate reconciliation showing contracted versus actual pass-through rates.

4

A compliance documentation section formatted to satisfy ERISA fiduciary review requirements and CAA 2026 disclosure obligations.

5

Specific, actionable recommendations for contract renegotiation, PBM RFP preparation, or ongoing monitoring.

You own the report entirely. You may share it with legal counsel, your board, plan participants, or use it as the basis for a PBM RFP. We have no ongoing financial interest in what you do with it.

Who We Work With

A clear view into pharmacy spend, PBM pricing, and where hidden costs may exist.

Typical Client Profile:

  • Self-insured or level-funded employers seeking greater cost visibility

  • Typically 150–1,500 covered lives

  • Pharmacy benefits administered through a PBM arrangement

When This Is a Good Fit:

  • Have not completed an independent PBM cost review in the past 1–2 years

  • Are approaching a PBM contract renewal or RFP cycle

  • Are evaluating your CAA 2026 compliance position

  • Have received pricing or spread disclosures you’d like to better understand

If you're unsure whether this applies to your plan, we’re happy to take a quick look and share an initial perspective.

What Makes This Independent

Glass River Analytics is compensated solely by the plan sponsor.
We do not receive fees, commissions, or incentives from PBMs, carriers, or benefits brokers.

In many benefit arrangements, compensation structures can influence how PBM performance is evaluated.
An independent review removes that dynamic and focuses solely on the underlying data.

Our role is to provide a clear, objective view of pharmacy spend - so decisions can be made with full transparency and confidence.

Start with a conversation.

We offer a free 30-minute initial consultation for self-insured employers who want to understand their PBM exposure before committing to a full engagement. No obligation. No sales pitch. Just an honest conversation about what you have and what we can find.