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Ownership and affiliate disclosure exhibit

Published findings, original references and room for an evidence-backed challenge.

What the rubric looks for

A signed exhibit lists every owner, parent, subsidiary, affiliate, group purchasing organization, rebate aggregator, mail order pharmacy and specialty pharmacy tied to the PBM, and the PBM must refresh it within 30 days of any change in ownership or control.

Why it matters

The model contract has no ownership exhibit, and the Nautilus Health Institute review of version 3.5 scored conflict of interest 70 of 100 for that gap. A plan cannot police affiliate pricing, steering or GPO pass through if it does not know which companies are affiliates.

OWN · Weight 3/100 · Introduced in rubric v2

Reference: Proposed Exhibit A-5

Only the selected record is loaded. Findings below are not a cross-contract tally or community activity.

Published evidence

Travis County · Envision Pharmaceutical Services, LLC

Published Commons finding

Not addressedFinding rubric version not recorded

No evidence quotation was recorded for this finding.

Recorded reference: No page reference recorded

Published rationale. All five models reached this verdict. No page contains a signed list of owners, parents, subsidiaries, group purchasing organizations, rebate aggregators or owned pharmacies, and nothing requires Envision to refresh such a list. The only corporate relationships named are the Costco partnership for mail and specialty on page 10 and the note on pages 4 and 8 that the outgoing vendor OptumRx is a United Healthcare subsidiary. The executed agreement is not part of this agenda backup and nothing in the 18 pages is redacted, so the subject is absent rather than unreadable.

“Not addressed” is this published review’s conclusion about the produced text, not proof that a provision is absent from every version or withheld document.

Inspect historical council readings (5 recorded for this criterion)

These are separately attributed readings of this record, not independent community contributions. Versions can differ; no new consensus has been calculated.

Claude Opus 5

Not addressedRubric v2 · Historical council reading

No evidence quotation was recorded for this finding.

Recorded reference: No page reference recorded

Published rationale. There is no ownership or affiliate exhibit anywhere in the 18 pages. The only corporate relationships named are Envision's mail and specialty partnership with Costco on page 10 and the fact that the outgoing pharmacy benefit manager, OptumRx, is a United Healthcare subsidiary, noted on pages 4 and 8. Neither is a signed disclosure of owners, parents, subsidiaries, group purchasing organizations or rebate aggregators, and nothing requires Envision to refresh such a list when ownership changes.

“Not addressed” is this published review’s conclusion about the produced text, not proof that a provision is absent from every version or withheld document.

Gemini 3.1 Pro

Not addressedRubric v2 · Historical council reading

No evidence quotation was recorded for this finding.

Recorded reference: No page reference recorded

Published rationale. The agenda backup does not contain the executed agreement or an ownership exhibit listing the PBM's affiliates and subsidiaries.

“Not addressed” is this published review’s conclusion about the produced text, not proof that a provision is absent from every version or withheld document.

GPT 5.6 Sol

Not addressedRubric v2 · Historical council reading

No evidence quotation was recorded for this finding.

Recorded reference: No page reference recorded

Published rationale. The Envision recommendation on pages 8 to 11 identifies a Costco partnership but does not provide a signed ownership and affiliate exhibit. No page lists owners, parents, subsidiaries, rebate aggregators, mail pharmacies, specialty pharmacies, or a 30-day update duty. The executed agreement and its exhibits are not in the packet.

“Not addressed” is this published review’s conclusion about the produced text, not proof that a provision is absent from every version or withheld document.

Grok 4.6

Not addressedRubric v2 · Historical council reading

No evidence quotation was recorded for this finding.

Recorded reference: No page reference recorded

Published rationale. No signed ownership exhibit appears in the eighteen pages. Page 10 mentions a Costco partnership for mail and specialty but does not list owners, parents, subsidiaries, affiliates, group purchasing organizations, or rebate aggregators, and does not require a refresh within 30 days after a change in control. The award memos and Gallagher notes on pages 8 through 11 and 16 through 18 do not fill that gap.

“Not addressed” is this published review’s conclusion about the produced text, not proof that a provision is absent from every version or withheld document.

Kimi K3

Not addressedRubric v2 · Historical council reading

No evidence quotation was recorded for this finding.

Recorded reference: No page reference recorded

Published rationale. No exhibit or passage lists Envision's owners, parents, subsidiaries or affiliates. The only affiliation mentioned is the Costco partnership for mail and specialty pharmacy on page 10, and it is not described as an ownership relationship. There is no obligation to refresh ownership information during the term.

“Not addressed” is this published review’s conclusion about the produced text, not proof that a provision is absent from every version or withheld document.

Document manifest and citation limits

Quotations and rationales are reproduced from published findings, not newly verified here. Named exhibits, amendments and ambiguous references must be checked in the document itself.

Community participation

Have contrary evidence, a missing exhibit or a question about the interpretation? Use the existing community composer to prepare a labelled finding. Publishing a community post is separate from a Commons review and does not change the contract score.

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PBM Commons · by BetterBuy RxEvidence is public. Interpretation is open to review.

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