EBSA Advisor Exits Following New PBM Disclosure Rule

Employers should prepare for the next phase of compliance as the agency shifts focus to implementing new PBM fee disclosure mandates.

Updated on Oct. 23, 2026 in Healthcare

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Senior Policy Advisor Caitlin Soto is departing the Employee Benefits Security Administration as the agency transitions to enforcing new pharmacy benefit manager disclosure rules. AI Illustration. Upload story photo >

Senior Policy Advisor Caitlin Soto is departing the Employee Benefits Security Administration, an agency that recently finalized new rules regarding pharmacy benefit managers and healthcare price transparency. Her exit follows the completion of key initiatives focused on disclosure and reporting within the employer-sponsored health benefits sector.

Why it matters

Soto led the Department of Labor's recent rulemaking on pharmacy benefit manager (PBM) fee disclosure, a critical compliance area for employers managing healthcare benefits. Her departure signals the transition from the development phase to the implementation and enforcement stage for these new regulatory standards.

The agency recently finalized rules concerning PBM fee disclosure standards for health plans, representing a significant shift from previous operational benchmarks. The full scope of how these disclosure requirements will impact plan administrator compliance remains under administrative review.

The players

Caitlin Soto

The departing Senior Policy Advisor at the Employee Benefits Security Administration who led recent PBM fee disclosure rulemaking.

Employee Benefits Security Administration

A division of the Department of Labor responsible for enforcing the Employee Retirement Income Security Act and regulating employer-sponsored health benefit plans.

Department of Labor

The federal executive department responsible for occupational safety, wage and hour standards, and the oversight of private-sector employee benefit plans.

The details

As a lead advisor, Soto directed the strategy behind the Department of Labor's push for increased transparency in PBM compensation structures. These rules aim to force greater visibility into how fees are negotiated and passed through to plan sponsors, directly affecting the operational cost modeling for businesses providing employee health benefits. Operators should prepare for changes in how they audit vendor contracts and report plan-related costs under the new regulatory framework.

Timeline

  1. October 23, 2026: Caitlin Soto announced her departure via LinkedIn.

  2. October 23, 2026: The official last day of work for the outgoing Senior Policy Advisor.

Market Landscape

This leadership transition follows the agency's recent focus on expanding transparency requirements within the framework of the Employee Retirement Income Security Act of 1974. It marks a shift from the creation of new disclosure mandates to the upcoming phase of operational compliance and agency enforcement.

Business owners should review their current pharmacy benefit management contracts to ensure they meet the updated fee disclosure requirements established under the latest rulemaking. Work with your benefits counsel to verify that your plan reporting practices remain compliant with these finalized standards as the agency shifts toward active enforcement.

The takeaway

The transition in agency leadership underscores that the era of PBM fee disclosure is moving from policy drafting to implementation. Operators should monitor forthcoming Department of Labor guidance for specific compliance audit timelines and document retention requirements for 2027 plan years.

Further reading

Learn more about the latest updates to Healthcare policy and compliance requirements.

Source note: This article includes information reported by Bloomberglaw.