This one couldn’t wait.

In this episode of The EOB Podcast, Justin and Julie break down the proposed Department of Labor rule on PBM transparency — and the flood of industry responses submitted before the comment deadline.

With over 500+ submissions from carriers, PBMs, employers, and other stakeholders, the conversation reveals a clear divide:

👉 Those pushing for more transparency 👉 And those… pushing back hard

For the first time, the proposed rule would require PBMs to disclose all compensation — including rebates, spread pricing, administrative fees, and more — before a contract is signed.

So why the resistance?

Justin and Julie dig into real comment letters from major players in the industry, breaking down:

• Common arguments against the rule (and what they really mean)
• Why “this is too complex” keeps coming up
• What employers are being told vs. what they actually need
• How transparency impacts fiduciary responsibility
• And where this could go next

Along the way, they call out contradictions, questionable logic, and a few moments that are… unintentionally hilarious.

Because when it comes to healthcare benefits: understanding how money flows isn’t optional — it’s the whole game.

What if the solution to rising healthcare costs isn’t more complexity… but more structure? In this episode of The EOB Podcast, Friends with Benefits Episode 2, Justin and Julie sit down with David Balinski, Founder & CEO of Wire Health, to challenge one of the biggest assumptions in healthcare:

👉 Should hospitals be treated like utilities?

From unpredictable pricing to lack of transparency and inefficient administrative systems, this conversation breaks down why the current healthcare model isn’t working — and what it might take to fix it.

David shares a bold perspective on how regulating hospital pricing could:

• Reduce extreme cost variation Improve access to care
• Shift competition toward quality and outcomes
• Eliminate billions in administrative waste
• Create a more sustainable system for employers and patients

The episode also dives into:

• Why healthcare lacks a true free market
• The illusion of price transparency
• How networks impact pricing and access
• The inefficiencies in claims processing and repricing
• Why employers and employees are both feeling the financial strain

If you’re an employer, HR leader, CFO, benefits advisor, or simply someone trying to understand why healthcare feels so broken… this episode connects the dots. Because when pricing doesn’t make sense… the system doesn’t either.

Gag clauses were officially banned under the Consolidated Appropriations Act (CAA)… so why are employers still struggling to access their own healthcare data?

In this episode of The EOB Podcast, Justin Leader and Julie Selesnick break down the real story behind gag clauses — what they are, why they were prohibited, and how they’re still impacting employers today.

While plan sponsors are now required to submit annual gag clause attestations confirming they have access to their data, many are finding that access is still limited, delayed, or controlled through internal “company policies” rather than explicit contract language.

This episode covers:

• What gag clauses actually are in healthcare contracts
• Why they were banned under the CAA
• How carriers and PBMs have adapted post-ban
• The challenges employers face when requesting claims and pricing data
• What the gag clause attestation requires (and why it matters)
• How to think about fiduciary responsibility and data access
• Practical steps employers can take to improve transparency

If you’re an employer, HR leader, CFO, broker, consultant, or plan fiduciary, this episode will help you better understand your responsibilities — and why simply signing an attestation isn’t enough.

Because when it comes to healthcare benefits, you can’t manage what you can’t see.

Follow for more conversations breaking down healthcare benefits, ERISA compliance, PBM transparency, and the real financial mechanics behind employer-sponsored health plans.

• The real story behind PBMs and pharmacy rebates
• Why GLP-1 drugs are driving pharmacy trend
• The economics behind drug formularies and rebate deals
• Why employers struggle to get transparent pharmacy data
• How plan sponsors can better manage pharmacy spend

In Episode 2 of The EOB Podcast, Justin Leader and Julie Selesnick break down the proposed U.S. Department of Labor rule that could become the most consequential PBM transparency regulation in decades. The proposed rule would require Pharmacy Benefit Managers (PBMs) to provide detailed disclosure of:

• Manufacturer rebates

• Spread pricing practices

• Pharmacy clawbacks

• Indirect compensation

• Affiliate & GPO relationships

• Audit rights and verification standards

But here’s the key: PBMs are already subject to compensation disclosure requirements under ERISA Section 408(b)(2) and the Consolidated Appropriations Act (CAA) of 2021.

So what makes this new rule different? Justin and Julie explain:

• Why employers cannot delegate fiduciary responsibility
• How rebate retention clauses can cost millions
• The impact of pharmacy clawbacks on independent pharmacies
• Why spread pricing is still a major issue
• What plan sponsors should be asking for in their RFPs right now
• Why you don’t need to wait for the rule to pass to demand transparency

If you are an employer, HR leader, CFO, broker, consultant, fiduciary, or compliance professional, this episode gives you a practical roadmap for reducing PBM risk and protecting your health plan. You don’t need a new law to start being proactive. Follow for more episodes breaking down healthcare benefits, ERISA compliance, fiduciary risk, PBM reform, and employer health plan strategy.