06/18/2026
A pharmacy savings strategy can look good on paper and still fail in the claims data.
One of the easiest places to see it is non-formulary spend. The benchmark is called the Formulary Compliance Rate:
Non-formulary drug spend ÷ total net drug spend × 100
If paid non-formulary spend is running above 3%, that should trigger a deeper review of exception approvals, therapeutic classes, reason codes, and whether the P&T committee’s work is being bypassed.
This is not about denying care. Good formulary management still allows fair, clinically appropriate exceptions.
But “access” should not become a shield for poor oversight, rebate-driven decisions, or special handling that undermines the plan’s clinical and financial intent.
A fiduciary standard of care requires employers to know whether the formulary is actually being followed, whether exceptions are documented, and whether coverage decisions are being made in the plan’s best interest.
If members are routinely filling non-formulary drugs, this is a clear signal why your healthcare savings strategy is failing.