One-pager · pharmacy & health-plan evidence

One engine, three possible markets.

The engine turns a pharmacy's or a health plan's own records into a claim-level fact pack where every dollar traces to a source row. Which market it serves first depends on which door opens — and that is where your contacts decide it.

As of September 21, 2026 · Hemang Nagar

What the engine does

It is evidence infrastructure, not a detection tool: it says what the record shows, reproducibly, and cannot invent a number.

Every figure traces to a source row. Claims, remittances, contracts and price benchmarks go in; each computed dollar carries the IDs of the records it came from, so a hostile expert or an auditor can re-trace it.
Same inputs, same output, every time. The calculation is deterministic and replayable, which is what a testifying expert or a fiduciary needs to defend a method as their own.
The narrative cannot state a dollar that is not in the fact pack. An AI writes the plain-English summary, but a gate rejects any amount not already computed.

Working demo on synthetic data — Medicare Maximum Fair Price refund reconciliation: hemangnagar.dev/rxguard-mfp
The MFP case is one join. The same engine runs against NADAC, PBM contract guarantees, or 340B rebates.

Three markets, one engine

The pharmacy ledger is the one we can start on now; the ERISA file is the biggest market; 340B has the nearest deadline. The right first market is the one where someone who already holds the data will run a paid pilot.

	Pharmacy claim ledger	ERISA plan-sponsor fiduciary file	340B rebate reconciliation
What it proves	Each claim paid below NADAC or contract; audit-ready proof pack per claim	Every plan dollar to the PBM traced: spread, rebate pass-through, admin fees vs. services	Each 340B rebate received vs. owed, claim by claim; denial reasons
Who pays	Plaintiffs' firms and claim organizers (TRUST LLC-type), audit-defense firms	Fee-only benefits consultants and PBM auditors, ERISA counsel; the employer behind them	Hospitals and health systems, via 340B consultancies
Clock	Court and arbitration deadlines; PBM audit windows of 14 to 60 days	Gag-clause attestation every Dec 31; RxDC June 1; CAA 2026 teeth from plan years after Aug 3, 2028	HRSA rebate pilot effective Jan 1, 2027; manufacturer 45-day data mandates now
Data access	Good: the pharmacy owns its records	Poor on big-3 PBM contracts until 2029; fine on transparent PBMs	Good: the covered entity owns everything, but PHI needs a BAA
Breadth	Narrow: a handful of organizers and firms	Largest: every self-funded employer	Medium: about 2,700 hospitals plus grantees
What we need from you	An intro to one firm or organizer for a fixed-fee pilot	An intro to one benefits consultant or ERISA lawyer	Anyone in hospital pharmacy or 340B

What changed in 2026

Each market rests on something that happened this year, not on a forecast.

Date	Event	Feeds
Sep 15, 2026	Arkansas pharmacies sue Express Scripts in federal court, the first suit under Act 990 (2025): about 48,300 claims allegedly paid below NADAC, statutory damages up to $10,000 per violation	Pharmacy ledger
Aug 27 & 31, 2026	Florida and Louisiana attorneys general sue Express Scripts and Prime over below-cost reimbursement to independents	Pharmacy ledger
Aug 3, 2026	HRSA publishes the revised 340B rebate pilot: manufacturer approvals Sep 24, effective Jan 1, 2027. The first version was enjoined and vacated in early 2026	340B
Jul 14, 2026	FTC consent order with CVS Caremark: plan sponsors must be allowed to move off spread pricing and rebate guarantees (Express Scripts order Feb 4)	ERISA
Mar 9, 2026	Stern v. JPMorgan Chase survives dismissal on prohibited-transaction counts; the court credited a per-drug price table (a 30-tablet generic at $6,229 plan-paid vs. $11 at Cost Plus)	ERISA
Mar 2, 2026	West Virginia insurance commissioner fines Express Scripts $1.5M after a market-conduct exam covering pharmacy reimbursement and audits	Pharmacy ledger
Feb 3, 2026	Consolidated Appropriations Act 2026 signed: PBMs become ERISA covered service providers; 100% rebate pass-through within 90 days of quarter end; semiannual NDC-level reports to plans; annual audit right; penalties up to $10,000 per day. Applies to plan years beginning on or after Aug 3, 2028	ERISA
Mar 17, 2025	NCPA's TRUST LLC files arbitration against CVS Caremark for 3,000+ assigned pharmacy locations	Pharmacy ledger

Still unsettled: Lewandowski v. J&J and Navarro v. Wells Fargo were dismissed on standing and are on appeal, with decisions expected in 2027. No PBM fee suit against an employer has settled yet.

Where your help decides it

Five answers, and the first market picks itself.

Pharmacy litigation. Do you know plaintiffs' counsel on the Arkansas Express Scripts case, or anyone at NCPA who can say how TRUST LLC collects assignor pharmacies' claim data today, and what it costs per pharmacy?
Audit defense. When your pharmacy was audited, who reconstructed the records, and what did the firm bill for that part? Would a firm you know pay a fixed fee for a 20-pharmacy pilot on a live matter?
ERISA. Do you know a fee-only benefits consultant, a PBM auditor, or an ERISA lawyer who would let us run one employer's claims extract under a BAA? That one file decides whether the ERISA market is reachable before 2029.
340B. Is anyone in your network in hospital pharmacy or 340B compliance?
The product itself. As a lawyer: would a machine-generated, reproducible, source-cited file change how you would defend or bring a case — or is it a nice-to-have next to what paralegals already produce?

What we are not asking for: money, or an introduction to any pharmacy that has not asked for one.

Sources

Dated facts above come from these pages. Vendor-published dollar figures (audit recovery averages, 340B float estimates) are left out because they could not be independently verified.