Transparency is no longer the differentiator, it’s the floor.

This week, the Federal Trade Commission issued a binding consent order against Express Scripts and its parent company, Cigna.

It wasn’t guidance. It wasn’t symbolic.

It was a 10-year mandate that fundamentally changes how pharmacy benefits are designed, priced, and disclosed.

And it affects every employer who offers health insurance.

For a long time, pharmacy pricing has been built around a system most employers never really saw. Rebates tied to inflated list prices. Spread pricing. Complex “guarantees” that sounded good on paper but were difficult to verify in practice.

Members often paid based on sticker prices. Employers were told it would “net out.” Few people had full visibility.

That system is now under direct federal pressure.

Under this new order, Express Scripts can no longer favor higher-priced drugs simply because they generate larger rebates. Members’ out-of-pocket costs must reflect the real, net cost of medications. Rebates and discounts must flow to members at the point of sale. Spread pricing is restricted. Compensation must be disclosed. Insulin affordability programs must be made broadly available.

In plain terms: opacity is no longer acceptable.

This matters because it sets a new baseline for what regulators now consider reasonable and responsible pharmacy benefit design.

When a more transparent, consumer-friendly model is federally required as a “standard offering,” choosing something less aligned is no longer just a budget decision. It becomes a governance decision. A fiduciary decision.

Employers are being asked—implicitly and increasingly explicitly—to understand how their pharmacy benefits actually work.

Who gets paid. How drugs are selected. Where rebates go. How member costs are calculated.

Those questions are no longer optional.

This shift is part of a larger trend across healthcare.

For years, the industry relied on complexity as a shield. If something was hard enough to understand, it rarely got challenged. But that era is ending. Regulators, courts, and plan sponsors are demanding clearer answers.

We are moving from “trust us, it works” to “show us how it works.”

At Level Health, this direction feels familiar.

Our pharmacy model has always been built around honest pricing, transparent contracts, and alignment with members and employers. No spread pricing. No incentive to inflate list prices. No reliance on rebate arbitrage. No favoring of higher list higher rebated products versus lower cost generics or biosimilars.

We believe healthcare decisions should be medical decisions, not financial engineering.

This FTC order doesn’t force us to change our philosophy. It reinforces it.

For employers, this is a good moment to pause and ask thoughtful questions about their current arrangements.

Do rebates flow to members at the pharmacy counter? Is pricing based on net cost or list price? Are all fees disclosed? Are incentives aligned with lowering total cost?

Clear answers build trust. Unclear answers deserve scrutiny.

While this order applies directly to one major PBM today, its influence will extend much further. It sets expectations. It shapes future enforcement. It changes what “normal” looks like.

Transparency is no longer a differentiator.

It is becoming the floor.

Healthcare works best when incentives are aligned. When employers understand what they are buying. When members understand what they are paying. When vendors are rewarded for lowering costs, not obscuring them.

That is where the industry is heading.

And it is where Level Health will continue to focus.