Nautilus Launched PBM Contract Scoring Framework
The new tool helps employers assess pharmacy benefit manager contracts for fiduciary and financial risk.
Updated on Sept. 22, 2026 in Healthcare
Live Poll
Should employers demand greater transparency and fiduciary accountability in pharmacy benefit manager contracts?
The Nautilus Health Institute introduced Contract X-Ray, a scoring framework that evaluates pharmacy benefit manager (PBM) contracts for financial integrity and fiduciary conduct. This initiative arrives as drug costs for U.S. employers are projected to rise by 12% in 2026.
Why it matters
Rising pharmaceutical costs and ongoing litigation over PBM fiduciary duties have pushed employers to demand more transparency in benefit management. The tool provides a standardized method for contract review, addressing a need for oversight identified by over half of industry brokers.
Nautilus reviewed 37 contracts using its new 10-point scoring system, where pass-through models averaged 92 compared to a 32 average for spread pricing agreements. With 2026 drug costs forecast to grow 12% versus 8.5% for general healthcare, employers are seeking better contract clarity.
The players
Nautilus Health Institute
An organization that produces health benefit research and develops diagnostic frameworks for employer contract evaluation.
Johnson & Johnson
A multinational medical devices, pharmaceutical, and consumer packaged goods manufacturing corporation.
JPMorgan Chase
A global financial services firm that acts as a major plan sponsor for employee benefits.
The details
The Contract X-Ray tool analyzes PBM agreements by evaluating 10 specific provisions rather than relying on vendor descriptions. It tests for fiduciary conduct, financial integrity, and oversight controls to identify hidden costs. This mechanism allows plan sponsors to benchmark their current agreements against industry standards before federal disclosure rules mandate new transparency in January 2029.
Timeline
2024: Employees filed a lawsuit against Johnson & Johnson regarding PBM fiduciary duty.
November 2025: A court dismissed the fiduciary claims against Johnson & Johnson.
2026: Drug costs for employers are projected to increase by 12 percent.
September 22, 2026: The Nautilus Health Institute publication date.
January 2029: New federal PBM disclosure requirements take effect.
Market Landscape
This scoring system acts as a proactive measure for plan sponsors navigating the lead-up to the 2029 federal PBM disclosure requirements. It follows a wave of litigation, including a 2024 case against Johnson & Johnson, that has challenged the traditional PBM fiduciary standard.
Employers should re-evaluate their current PBM agreements to determine if they rely on spread pricing, which currently yields lower transparency scores. Review your existing contract language against the 10-point framework before 2029 to anticipate coming federal disclosure obligations.
The takeaway
Transparency in PBM contracts is becoming a prerequisite for managing the 12% rise in 2026 drug costs. Operators should audit their current contract provisions to align with evolving fiduciary expectations well before the 2029 federal deadline.
Further reading
For more on evolving standards, see our Healthcare section.
Live Poll
Should employers demand greater transparency and fiduciary accountability in pharmacy benefit manager contracts?
