Congress Enacts 2026 Consolidated Appropriations Act, Amends Tax Provisions (§9826)

Congress enacted the Consolidated Appropriations Act, 2026 into law. The law includes: 1) IRC § 9826, which mandates pharmacy benefit managers (PBMs) to provide transparency reports to group health plans on drug spending, rebates, and spread pricing for plan years starting 30 months after the date of enactment; 2) IRC § 9831(a)(2) amendments narrowing the small employer exemption to ensure PBM transparency requirements apply to all group health plans regardless of size; and 3) IRC § 4980D(g) modifications imposing excise tax penalties of $100 per day per affected individual on plan sponsors failing to ensure PBM compliance with the new ...