Lexology January 13, 2026
Alternative prescription drug access models—including direct-to-employer (DTE) and direct-to-consumer (DTC)—are gaining traction as employers reassess traditional pharmacy benefit manager (PBM)-based pricing structures. As these models expand, plan sponsors must evaluate their impact on plan design, fiduciary oversight, data transparency, and PBM contracting.
For decades, employer-sponsored group health plans have relied on PBMs to manage prescription drug access and pricing. That model remains firmly in place in 2026, but it is increasingly being supplemented by alternative pathways that change how certain drugs are purchased, priced, and delivered. These emerging models, including DTE, DTC, and government-backed pricing initiatives, are not replacing PBMs, but they are creating parallel channels that challenge long-standing assumptions about how drugs are purchased and delivered. For plan sponsors,...
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