Nautilus Health Released Pharmacy Benefit Scoring Tool
A new framework evaluates pharmacy benefit manager contracts for fiduciary integrity and financial transparency.
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 has launched Contract X-Ray, a scoring framework designed to assess pharmacy benefit manager agreements for fiduciary conduct and financial oversight. The tool aims to provide clarity for employers as drug cost growth outpaces overall healthcare spending.
Why it matters
With employer drug costs projected to rise 12% in 2026, the tool addresses widespread broker concerns regarding fiduciary oversight gaps. The framework provides a standardized method to evaluate contract quality, helping employers navigate complex PBM arrangements.
The Nautilus Health Institute reviewed 37 plan sponsor contracts, finding a wide disparity between pricing models. One contract scored only 29 out of 100 on the new framework, which analyzes 10 specific provisions for financial integrity.
The players
Nautilus Health Institute
This organization develops research and frameworks focused on improving healthcare benefit management and transparency.
Johnson & Johnson
This multinational corporation faced legal challenges regarding its oversight of pharmaceutical benefit management programs.
JPMorgan Chase
This financial services firm is currently involved in litigation regarding alleged prohibited transactions related to pharmacy benefit management.
The details
The Contract X-Ray framework evaluates contract language instead of relying on manufacturer descriptions to measure fiduciary conduct and oversight control. This technical analysis provides employers with a quantitative method to identify risks in their current benefit agreements.
Timeline
A 2024 lawsuit challenged Johnson & Johnson over PBM fiduciary duties.
Courts dismissed fiduciary claims against Johnson & Johnson in November 2025.
Drug costs are projected to increase 12 percent in 2026.
Federal PBM disclosure requirements are scheduled to take effect in January 2029.
Market Landscape
The introduction of this scoring framework tracks with a broader industry shift toward increased scrutiny of opaque pharmacy pricing practices. This move forces a competitive environment where contracts lacking transparency face greater scrutiny from plan sponsors ahead of upcoming federal disclosure mandates.
Employers using this framework may gain leverage to negotiate better terms or shift toward transparent pricing models. This could potentially reduce the growth rate of employee drug costs by identifying and mitigating hidden expenses in plan agreements.
The takeaway
Standardized scoring tools allow employers to move beyond complex PBM marketing materials to see the underlying financial mechanics of their contracts. Implementing these assessment protocols now may help organizations prepare for the compliance demands of future federal disclosure rules.
Further reading
Learn more about evolving standards in Healthcare.
Live Poll
Should employers demand greater transparency and fiduciary accountability in pharmacy benefit manager contracts?
