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PBM Governance

Building trust through PBM transparency.

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PBMs must adhere to strict governance standards that are contractually binding

These standards and disclosure rules give our clients transparency into the architecture of each pricing model, helping them to choose the arrangement that best suits their needs.

Express Scripts provides a detailed disclosure to clients of its principal revenue sources, including arrangements with pharmaceutical manufacturers and pharmacy claims insights, as well as information on rebates and administrative fees. Clients also have an annual right to audit our performance and adherence to contract terms.

Transparency for clients

Express Scripts provides clients with information on our principal revenue sources. This includes arrangements with pharmaceutical manufacturers and retail pharmacy claims, as well as rebates and administrative fees.

For reporting purposes, PBMs report administrative fees paid directly by clients as direct compensation for Schedule C, Form 5500. The Form 5500 Series is a formal disclosure intended to ensure that employee benefit plans are operated and managed in accordance with certain standards. Beginning in 2023, Express Scripts will also provide additional financial and fee disclosures to clients that have elected spread pricing.

Sharing this information with clients helps them evaluate their PBM pricing options on an “apples-to-apples” basis and select the model that provides the most value to their members.

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To promote additional transparency, clients have full audit rights to ensure Express Scripts is performing according to the terms of our contracts.

All Express Scripts clients can audit the financial components of their contracts on an annual basis and have the right to appoint third party auditors.

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Many of Express Scripts’ clients are sophisticated purchasers, and all employers are represented by brokers who bring a deep knowledge of the benefits industry, conduct analyses of the potential value provided by the PBM, and provide advisory services when selecting a PBM
and negotiating a contract.

PBMs have no financial connection to these consultants.

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