Health plans typically retain consulting firms to assist health plans in (i) conducting PBM RFPs, (ii) conducting PBM audits, and (iii) drafting and negotiating PBM contracts. Unfortunately, unbeknownst to health plans, their consulting firms frequently have conflicts of interest. In fact, many consulting firms have undisclosed brokerage relationships with PBMs, and most consulting firms are receiving large amounts of money from PBMs.

Accordingly, if your health plan intends to retain a consulting firm, it is imperative that you require your consulting firm to execute a Conflict of Interest Disclosure Form. Pharmacy Benefit Consultants has drafted a model Disclosure Form and Agreement for your health plan to use, and you can download it for free:

Download: DISCLOSURE FORM and AGREEMENT

If your health plan has already retained a consulting firm, and you did not vet its potential conflicts of interest, do so now. It’s never too late to learn whether your consultants have undisclosed relationships that may cause them to act against your health plan’s interests!

For further information about the potential impact of consulting firms’ conflicts of interest, consult the following Department of Labor proposed regulations concerning service providers’ disclosure obligations:

Download: Dept of Labor, 29 CFR Part 2550

For a free consultation about consultant firms’ conflicts of interest, or any other matter related to your health plan’s prescription benefit coverage,

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