CMS filed a 265-page rule in October 2026 that ends spread-based pharmacy benefit manager pay in Medicare and grades every Medicare Advantage plan’s provider directory. Both take effect in 2028. Neither gives the industry two years.
Part D bids for 2028 are due June 2027. Every pharmacy benefit manager contract built on spread, rebate retention, or volume-based fees has to be rebuilt before those bids go in. The real deadline is spring 2027.
On the directory side: CMS reviewed 142 Medicare Advantage organizations from 2022 to 2024 and found 44% of location listings had at least one deficiency. That number is basically a preview of the letter grade every plan will receive starting in 2029.
CMS admits in its own impact table that it cannot estimate the financial effect of the pharmacy benefit manager provisions. Reason: nobody outside the pharmacy benefit managers knows what the current contracts say. That sentence is the whole reason the law exists.
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