Your Drug Bill Is a Yield Product
The hidden economics inside a pharmacy benefit
Mitchell McLennan
Founder · Wavestar Holdings · September 29, 2026 · 3 min read
The prescription counter is one of the last places a person expects to encounter a financial instrument. A physician writes for a drug. A pharmacist dispenses it. The employer pays for a benefit it promised to its workers. Yet between those three acts sits a set of contracts that can turn the same prescription into different prices for the patient, the plan, and the pharmacy.
The pharmacy benefit manager is paid to administer that space. It builds a network, processes claims, negotiates rebates, and helps determine which drugs receive favorable formulary placement. None of those functions is imaginary. A national plan needs someone to do the work. The question is how that intermediary earns money while doing it, and who can see the answer.
The Federal Trade Commission's second interim PBM report examined 51 specialty generic drugs administered by the three largest PBMs from 2017 to 2022. FTC staff found that their affiliated pharmacies generated more than $7.3 billion in dispensing revenue above an estimated acquisition-cost benchmark on those drugs. The agency separately estimated $1.4 billion in spread-pricing income on the studied drugs, meaning the PBMs billed plan sponsors more than they reimbursed pharmacies. Those are findings about a defined set of drugs and a defined period, not a universal margin for every prescription. Their significance lies in the number of different places revenue can sit along one transaction.
That makes a drug bill hard to read. The plan sponsor sees its invoice. The pharmacy sees a reimbursement. The patient sees a copay. A manufacturer rebate may arrive later, through an affiliate, under a contract whose terms are not visible at the counter. Even a promise to pass rebates through can leave open questions about fees, timing, and which price the patient's share was calculated from. The party buying the benefit may have a perfectly legible expense without a legible account of the economics that produced it.
This is where the yield metaphor earns its keep. A plan purchases a pharmacy benefit for access and risk protection. The intermediary can also earn from routing, reimbursement differences, negotiated concessions, and affiliated dispensing. The return is embedded in the movement of the claim. Calling the bill a yield product does not mean every PBM makes money the same way or that every rebate is retained. It means the buyer has to inspect the entire path of compensation rather than infer it from a single administrative fee.
Regulators have begun to put that inspection obligation into plainer language. In January 2026, the Department of Labor proposed a rule for PBMs serving self-insured ERISA plans. It would require disclosure of direct and indirect compensation so plan fiduciaries could assess whether their arrangements are reasonable and verify the figures. It remains a proposal; the disclosure regime described in it should not be mistaken for a rule already in force. But the proposed test is the right commercial question now: can the buyer reconcile the compensation with the service and the claim?
The answer takes more than a lower headline price. An employer needs a contract that accounts for rebates, spreads, affiliated-pharmacy payments, and other fees. It needs enough claim-level detail to test that account, with a right to audit rather than an invitation to trust a summary. The patient needs a price that can be explained at the counter without a private glossary. Pharmacies need to know whether reimbursement reflects the same rules applied elsewhere in the network.
There is no need to pretend that intermediaries disappear when the contracts get clearer. Their work is real. So is the risk that an opaque compensation path changes what gets preferred, where a prescription is filled, and what everyone believes the medicine costs. A benefit worthy of the name should let its buyer follow the money through one claim without having to hire a forensic accountant.
Sources: FTC, second interim staff report (Jan. 14, 2025): https://www.ftc.gov/news-events/news/press-releases/2025/01/ftc-releases-second-interim-staff-report-prescription-drug-middlemen
Department of Labor, proposed PBM fee-disclosure rule (Jan. 30, 2026): https://www.federalregister.gov/documents/2026/01/30/2026-01907/improving-transparency-into-pharmacy-benefit-manager-fee-disclosure
Originally published on
mitchellmclennan.substack.com

