Is Your PBM’s Transparency Just Marketing?

October 2025
Pharmacy benefit managers love to talk about transparency. You’ve heard the pitch- “We’re pass-through,” “we’re aligned with your goals,” or “we operate with full transparency.” But when you look at the numbers, or try to get answers, and you’re left wondering, “If this is transparency, why can’t I see what’s really happening?

If that sounds familiar, you’re not alone. Many plan sponsors are waking up to the gap between what’s being promised and what’s being delivered.

It’s time to ask a simple question with real consequences:
Is your PBM actually transparent, or are they just using the language of transparency to keep you comfortable with the status quo?

Transparency Has Become a Buzzword

In today’s market, every PBM claims to be transparent. It’s become table stakes in RFPs and sales conversations. But just because a PBM uses the right words doesn’t mean they’ve changed how they operate.

We’ve seen too many contracts labeled “pass-through” that still bury revenue in obscure network spreads or carve-outs. We’ve seen “aligned” PBMs lock clients into mail-order networks they control. We’ve seen “100% rebate pass-through” promises that come with vague definitions and zero source-level documentation.

The language of transparency is being used as a shield to avoid actual scrutiny.

Why Plans Still Aren’t Seeing Results
The biggest clue that your PBM’s transparency claims aren’t real? You’re not seeing meaningful change.

• • • Your drug spend isn’t going down, even with a new “transparent” PBM.
    • You don’t have access to claims-level pricing, rebate breakdowns, or contract performance.
    • Your clinical programs still feel generic, and member experiences haven’t improved.

The promises are there, but the results are missing. That’s because many so-called transparent PBMs are still built on the same legacy incentives: make more when you spend more, hide margins in complexity, and limit the client’s visibility wherever possible.

How to Spot Real Transparency

Let’s make this more practical. If your PBM is truly transparent, you should be able to confidently answer these questions:

1. Do you have access to every line item, what the PBM paid the pharmacy and what you paid the PBM for each drug?
If not, you’re operating in the dark. True transparency gives you claims-level data with full visibility into pricing.

2. Are 100% of rebates and manufacturer incentives passed back to you, with reporting to verify?
Watch for vague language around “eligible” rebates or “retained” discounts. That’s often where margin hides.

3. Are there any hidden fees in mail order, specialty pharmacy, or clinical program administration?
Even if the retail spread is removed, revenue can reappear in other corners of the contract.

4. Do you have full audit rights with access to raw data, not just summarized reports?
If your audit scope is limited or mediated through the PBM, that’s a red flag.

5. Can you carve out services, such as specialty or prior auth, and compare vendors?
Real transparency means unbundled options and competitive pressure.

6. Are your clinical programs aligned to patient outcomes—or just savings projections?
Transparency is about behavior, not just spreadsheets. The clinical model should support members, not just reduce utilization.

If you’re unsure about any of these, your PBM may be marketing transparency more than practicing it.

Transparency Needs to Be a System, Not a Slogan

At Crystal Clear Rx, we don’t believe transparency is a communication strategy. It’s a structural decision. It’s built into how the contract works, how revenue flows, how decisions are made, and how you, the plan sponsor, stay in control.

It means:

• • • A fixed, disclosed admin fee instead of earning margins on utilization.
    • Contracts that allow full audit rights, no redactions.
    • Independent clinical oversight that separates cost control from patient care.
    • Rebate and discount data traceable to the source, with nothing held back.
    • Reporting that shows you not just what happened, but why and what you can do about it.

When transparency is real, trust becomes measurable. Your team can track what’s working. You can see when changes are needed. And you know exactly what you’re paying for and why.

You Deserve More Than a Marketing Message

Your fiduciary responsibility demands more than good-sounding language. It requires proof. Visibility. Control.

If you’ve been told your PBM is transparent, but you’re not seeing better outcomes, ask yourself, “What does transparency mean to them, and what should it mean to you?”

Head over to Crystal Clear Rx website to take a look at common PBM cost tactics on Our Blog or Contact Us for help.