News & Analysis as of

Pharmacy Benefit Manager (PBM) Reporting Requirements

Bricker Graydon LLP

Is My Group Health Plan Covered by State PBM Reporting Laws?

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State laws seeking to regulate pharmacy benefit managers (PBMs) have increased significantly over the past few years. As it stands, all 50 states have laws that regulate PBMs in some way, but all are unique. However, most of...more

Quarles & Brady LLP

Indiana Senate Bill 140 Signed into Law Imposing Reforms on Pharmacy Benefit Managers

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Indiana recently enacted significant new legislation that will impact how pharmacy benefit management services are provided in Indiana. Senate Bill 140 (SB 140), signed into law during the 2025 legislative session, imposes...more

Mintz - Health Care Viewpoints

PBM Legislation in the Reconciliation Bill is Far From Sweeping PBM Reform

Over the past few years, Congress has attempted to pass “federal PBM reform.” Members of Congress have held numerous hearings related to PBMs and introduced numerous bills seeking to regulate PBMs (we regularly track these...more

Bass, Berry & Sims PLC

Indiana Enacts Legislation Affecting Health Care Transactions and Imposing Ownership Reporting Requirements

Bass, Berry & Sims PLC on

On May 6, 2025, Indiana Governor Mike Braun signed Indiana HB 1666 into law. This new law grants Indiana’s attorney general authority to investigate market concentration of health care entities, modifies existing requirements...more

Bass, Berry & Sims PLC

Stuck in the Middle: Self-Funded Health Plans and Recent Challenges to State PBM Laws

In recent years, prescription drug prices have been top-of-mind for state legislators, who have responded by passing laws that seek to control that pricing in a variety of ways, including by regulating pharmacy benefit...more

ArentFox Schiff

Massachusetts Enacts Drug Pricing Legislation: Introducing PBM Licensure, Mandatory Cost Reporting, and Consumer Cost-Sharing...

ArentFox Schiff on

On January 8, Massachusetts Governor Maura Healy signed into law “An Act Relative To Pharmaceutical Access, Costs And Transparency.” The Act will have a profound impact on all parties involved in setting and applying drug...more

Mintz - Health Care Viewpoints

Massachusetts Aligns with National Trends and Enacts Sweeping Legislation to Regulate Pharmaceutical Benefit Managers

On the heels of a nationwide push to regulate pharmacy benefit managers (PBMs), Massachusetts enacted a landmark piece of legislation to increase transparency and oversight within the pharmaceutical supply chain, specifically...more

Bass, Berry & Sims PLC

Massachusetts HB5159 Expands Oversight of Private Equity Investment in the Health Care Industry

Bass, Berry & Sims PLC on

On January 8, the governor of Massachusetts signed House Bill 5159 into law (Law). At a high level, the new Law expands Massachusetts’ existing health care transaction notice process and implements new reporting and oversight...more

Epstein Becker & Green

Massachusetts Governor Maura Healey Signs into Law a Sweeping Health Care Market Oversight Bill

Epstein Becker & Green on

On January 8, 2025, Massachusetts Governor Maura Healey signed into law House Bill No. 5159, “An Act enhancing the health care market review process” (“H. 5159”), which was passed by the Massachusetts legislature in the last...more

Mintz - Health Care Viewpoints

It’s Been a Long Time Coming: Massachusetts Health Care Market Review 2.0

The latest entrant in a national wave of policymakers enacting health care market oversight laws that have a significant impact on providers and investors, Massachusetts Governor Maura Healey has signed into law House Bill...more

Husch Blackwell LLP

Massachusetts Legislature Passes Bill Expanding Healthcare Industry Oversight

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On December 30, 2024, the Massachusetts Legislature passed House No. 4653, “An Act Enhancing the Health Care Market Review Process.” This bill includes sweeping changes focused on increased regulatory oversight and healthcare...more

Wiley Rein LLP

Proposed State and Federal PBM Legislation: Is There Reason for Action Now?

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Legislation aiming to reform the regulation of pharmacy benefit managers (PBMs) remains on the horizon on both the federal and state levels. In particular, 2023 was a fertile year for PBM legislative initiatives....more

Verrill

RxDC Reporting in Light of June 1, 2024 Deadline and Recent PBM Litigation

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Under the Consolidated Appropriations Act of 2021 (“CAA”), employer-sponsored group health plans, including medical-only plans, must submit information about their prescription drugs and health care spending. This submission...more

McDermott Will & Emery

New York Withdraws Proposed Market Conduct Regulations for PBMs, Adopts Licensure Rules

McDermott Will & Emery on

On October 31, 2023, the New York State Department of Financial Services (DFS) released a notice withdrawing its proposed market conduct rules for pharmacy benefit managers (PBMs). The proposed rules, announced August 16,...more

Snell & Wilmer

2023 End-of-Year Plan Sponsor “To Do” Lists (Part 1) Health and Welfare

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We are pleased to present our annual End of Year Plan Sponsor “To Do” Lists. This year, we present our “To Do” Lists in four separate Employee Benefits Updates. This Part 1 covers year-end health and welfare plan issues....more

Holland & Knight LLP

Holland & Knight Health Dose: October 3, 2023

Holland & Knight LLP on

Holland & Knight Health Dose is an in-depth weekly dose of legislative and regulatory insights to keep stakeholders abreast of happenings in Washington, D.C., impacting the health sector. ...more

Morgan Lewis

New Jersey Latest to Join States Signing Drug Price Transparency Reporting Measures into Law

Morgan Lewis on

Following in the footsteps of other states, New Jersey’s state legislature has recently signed into law three bills for containing prescription drug costs. One bill—Senate Bill 1615—is likely to have a particularly sweeping...more

Mintz - Health Care Viewpoints

Pharmacy Benefit Managers are on the Federal Government’s Radar: Senate, House, and Agency Proposals Seek to Increase PBM...

Bipartisan legislative activity related to pharmacy benefit manager (PBM) oversight is at an all-time high in both the House and Senate. As we noted last week, several bills that address PBM activities are moving through the...more

Mintz - Health Care Viewpoints

Pharmacy Benefit Managers are on the Federal Government’s Radar: Senate, House, and Agency Proposals Seek to Increase PBM...

In conjunction with the surge in state legislative efforts to regulate the pharmacy benefit manager (PBM) industry, Congress and federal agencies have ramped up PBM oversight efforts as part of the ongoing battle to lower...more

Woodruff Sawyer

Agencies Release Revised Instructions for 2022 Reference Year RxDC Reporting

Woodruff Sawyer on

On March 3, 2023, federal agencies released revised Prescription Drug Data Collection (RxDC) Reporting Instructions applicable to the 2022 reference year. RxDC reporting for the 2022 reference year is due on or before June 1,...more

Laner Muchin, Ltd.

Reminder: Deadline for Prescription Drug and Certain Medical Claim Reporting is December 27, 2022

Laner Muchin, Ltd. on

The 2021 Consolidated Appropriations Act (CAA) established new transparency requirements for group health plans to report specific information about prescription drugs and health care spending to the Centers of Medicaid and...more

Mintz - Health Care Viewpoints

New York Establishes First Pharmacy Benefits Bureau in the Nation as Registration and Annual Reporting Deadlines for Pharmacy...

On May 11, 2022, New York Governor Kathy Hochul announced the creation of the Department of Financial Services’ Pharmacy Benefits Bureau. Governor Hochul noted that the Pharmacy Benefits Bureau is the first of its kind in the...more

Mintz - Health Care Viewpoints

New York To Require Licensure of Pharmacy Benefit Managers

In an effort to counteract rising prescription drug costs and health insurance premiums, New York Governor Hochul signed S3762/A1396 (the Act) on December 31, 2021. This legislation specifies the registration, licensure, and...more

Foley & Lardner LLP

New Prescription Drug and Health Care Spending Reporting Requirements from a Carrier and Plan Service Provider Perspective

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Under the Consolidated Appropriations Act, 2021 (the “CAA”), group health plans and health insurance issuers are required to submit certain information related to prescription drug and other health care spending to the...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Making a List, Checking It Twice: Year-End Guidance on Drug Cost Reporting

Employers and their benefit administrators have more detail and a more convenient way to submit “top 50” lists and other data - but no more time to comply with - daunting prescription drug cost reporting requirements in the...more

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