Cigna & the PBM Conflict of Interest Question

Ongoing litigation involving pharmacy benefit managers and their affiliated health plans has placed the fiduciary obligations of group health plan sponsors under renewed scrutiny. Plan sponsors are increasingly expected to document their PBM selection and oversight process in the same manner as investment manager due diligence.

The conflict of interest concerns at the center of PBM litigation reflect a structural issue that plan sponsors must now actively address: when a PBM has financial incentives that may not align with the plan's interest in minimizing costs and maximizing participant benefit, the plan sponsor bears responsibility for understanding and managing that conflict.

Regency works with group health plan sponsors to evaluate PBM arrangements independently — assessing cost transparency, rebate pass-through practices, formulary construction, and contractual terms against a market standard built on unconflicted analysis.