# Which States Regulate PBMs Most Heavily? | USLege

> Louisiana and Arkansas regulate PBMs most heavily; Wyoming regulates them least. See every state's PBM regulation score, built from live USLege bill data.

Canonical: https://www.uslege.ai/reports/pbm-regulation

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Reports · 2025-2026 sessions

# Which states regulate PBMs most heavily?

Louisiana and Arkansas regulate pharmacy benefit managers most heavily in the country, each scoring just 8 out of 100 on this report's PBM regulatory-freedom index after enacting a stack of comprehensive reform laws: reimbursement floors, anti-steering and ghost-network bans, PBM licensure, and enforcement funds. Wyoming, South Dakota, and New Hampshire regulate PBMs the least, having introduced no PBM-specific bills at all this session. Here's the score for all 48 states USLege found PBM bill activity in, built from live bill-tracking data.

![Laura Davis](/assets/headshots/laura-davis-founder.avif)

By [Laura Davis](https://lauraluisedavis.com/), Co-Founder & Chief Business Officer at USLege.

**Methodology:** each state is scored 0-100 across five weighted factors measuring PBM regulatory freedom: freedom from comprehensive reform (25 pts), few PBM mandates (20), light enforcement with no fiduciary duty imposed (20), business-model freedom (20), and limited regulatory reach (15), using every 2025-2026 session bill USLege's database returned for the topic. A lower score means heavier PBM regulation; a higher score means a lighter regulatory touch. Sources: USLege's live legislative tracking database (bill data current through mid-July 2026) plus state statute and session-law research. Montana and Nevada have essentially no indexed PBM bill activity in USLege and are shown gray, unscored, rather than assigned a score.

Every state legislature has taken up pharmacy benefit manager reform in some form, but how far a state actually goes (spread-pricing bans, reimbursement floors, anti-steering rules, licensure, audit and enforcement authority) varies enormously. This report scores 48 states on that regulatory intensity, then shows the actual bills and sponsors behind each score session by session on the [USLege platform](/platform), not just a policy summary, but who is pushing to expand or restrict PBM oversight right now.

48

states scored

255

bills analyzed

8–72

score range

Louisiana

heaviest regulation

Lower Higher No data

Lighter shading means a lower score (more comprehensive, stacked PBM reform). Darker shading means a higher score (fewer PBM-specific mandates on the books this session).

## Top 12 states regulating PBMs most heavily

#48 of 48

#48

## Louisiana

Most Restrictive

Louisiana has enacted a run of comprehensive PBM reform laws across the 2025 and 2026 sessions: HB 264 (2025, Act 474, gov. signed; companion SB 194 died in committee) banned spread pricing, restricted PBM revenue to management fees, and mandated NADAC-plus-dispensing-fee reimbursement with commissioner audits; HB 1236 and SB 387 (2026; SB 387 = Act 914, eff. Jan 1, 2027) layered on a standardized NADAC reimbursement formula and appeals process, fee-only PBM compensation restrictions, mandatory annual audits, and reverse-auction procurement for state PBM contracts; SB 401 (2026, effective) created a Prescription Drug Affordability Board. Two more bills remain pending: HB 938 (a further comprehensive PBM overhaul, recommitted to Finance) and SB 369 (a Medicare-benchmark reimbursement floor for the state's Office of Group Benefits, stalled on the calendar).

Freedom from Comprehensive Reform1/25

Few PBM Mandates2/20

Light Enforcement / No Fiduciary Duty3/20

Business-Model Freedom1/20

Limited Regulatory Reach1/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

Jimmy Harris

Democratic · Dist. 4

SB 194

Sponsored the original 2025 PBM revenue-restriction/spread-pricing ban and its 2026 successor (SB 377).

Michael Echols

Republican · Dist. 14

HB 264

Sponsored the 2025 enacted reimbursement-floor and anti-steering law; also carries the pending HB 1217 enforcement-fund bill.

Jason DeWitt

Republican · Dist. 25

HB 1236

Sponsored the enacted NADAC reimbursement-formula law.

Adam Bass

Republican · Dist. 36

SB 387

Sponsored the enacted comprehensive PBM duty-of-care law and the pending Medicare-benchmark reimbursement bill (SB 369).

Kirk Talbot

Republican · Dist. 10

SB 401

Sponsored the enacted Prescription Drug Affordability Board law.

Christopher Turner

Republican · Dist. 12

HB 938

Sponsored the pending comprehensive PBM overhaul, currently in Finance.

**Why it matters:** Louisiana is now among the most aggressively PBM-regulated states in the country: reimbursement floors, spread-pricing bans, fee-only compensation, mandatory audits, and reverse-auction procurement are all law, placing it firmly at the reform-forward end of the axis rather than a light-touch market.

### Bills

SB 194Provides relative to pharmacy benefit managersRestrictive

Restricts PBM revenue to management fees only, bans spread and effective-rate pricing especially for local pharmacies, and mandates contract transparency and annual audits by the insurance commissioner or health plans.

**Sponsor:** Jimmy Harris (Democratic–4)**Status:** Died in Senate Insurance Committee (2025); enacted 2025 PBM law was HB 264 / Act 474**Category:** Comprehensive PBM revenue & transparency reform

[View on USLege →](https://app.uslege.ai/bills/2093989)

HB 264Provides for transparency and compensation practices relative to pharmacy benefit managersRestrictive

Prohibits PBM retention of manufacturer rebates and spread pricing, mandates reimbursement of local pharmacies at or above acquisition cost, requires transparency reports and an appeals process, and creates a commissioner-run enforcement fund.

**Sponsor:** Michael Echols (Republican–14)**Status:** Enacted: effective 06/20/2025**Category:** PBM reimbursement floor & anti-steering

[View on USLege →](https://app.uslege.ai/bills/2093363)

HB 1236Provides relative to pharmacy benefit managers reimbursementsRestrictive

Redefines acquisition cost as the actual cost paid by local pharmacies, mandates NADAC/WAC-based reimbursement plus a professional dispensing fee, establishes a standardized appeals process, and bars PBMs from recouping the dispensing fee.

**Sponsor:** Jason DeWitt (Republican–25)**Status:** Enacted: Act 913, signed 06/12/2026**Category:** NADAC reimbursement formula

[View on USLege →](https://app.uslege.ai/bills/3872724)

SB 377Provides relative to pharmacy benefit managersRestrictive

Restricts PBMs to earning only fees commensurate with services rendered, prohibits retention of rebates and fees, mandates transparency and commissioner/insurer audits, and bans spread pricing.

**Sponsor:** Jimmy Harris (Democratic–4)**Status:** Pending Senate Insurance Committee (2026); substance carried by SB 387 / Act 914**Category:** Fee-only PBM compensation mandate

[View on USLege →](https://app.uslege.ai/bills/3858701)

SB 387Provides relative to pharmacy benefit managersRestrictive

Establishes PBM duties of care and transparency to enrollees/health plans/providers, restricts compensation methods, mandates annual audits and formulary-management rules, and requires reverse-auction procurement for state PBM contracts.

**Sponsor:** Adam Bass (Republican–36)**Status:** Enacted: Act 914, effective 01/01/2027**Category:** Comprehensive PBM duty-of-care regime

[View on USLege →](https://app.uslege.ai/bills/3858715)

SB 401Provides for a Prescription Drug Affordability BoardRestrictive

Creates a Louisiana Prescription Drug Affordability Board within the Department of Insurance to build a critical-drug list, collect pricing/cost data from manufacturers, and publish public pricing reports.

**Sponsor:** Kirk Talbot (Republican–10)**Status:** Enacted: Act 915, effective 08/01/2026**Category:** Prescription Drug Affordability Board

[View on USLege →](https://app.uslege.ai/bills/3862384)

HB 938Provides relative to pharmacy benefit managersRestrictive

Expands the PBM definition and imposes reimbursement standards requiring payment at or above NADAC-plus-dispensing-fee, limits PBM revenue to flat fees/performance bonuses, mandates rebate pass-through, and requires reverse-auction procurement for state PBM contracts.

**Sponsor:** Christopher Turner (Republican–12)**Status:** Pending: recommitted to Committee on Finance, May 14, 2026**Category:** Comprehensive PBM overhaul

[View on USLege →](https://app.uslege.ai/bills/3858650)

SB 369Provides for prescription drug pricingRestrictive

Would bar manufacturers from selling drugs to Louisiana's Office of Group Benefits above Medicare prices and bar insurers/PBMs from reimbursing below Medicare prices for those drugs under state-sponsored plans.

**Sponsor:** Adam Bass (Republican–36)**Status:** Stalled: read by title and returned to the Calendar, Apr 8, 2026**Category:** Medicare-benchmark reimbursement floor

[View on USLege →](https://app.uslege.ai/bills/3858693)

### Who testified: stakeholders on the record · 6 on the record

### Testified FOR PBMs (against new regulation) · for

Phil Cristofanelli

Pharmaceutical Care Management Association (PCMA)

HB 264

Testified in opposition to HB264's point-of-sale rebate mandate, arguing it would eliminate manufacturer rebates and raise premiums for patients and plans.

George Guidry

Koch Industries / Georgia-Pacific (self-insured employer)

HB 264

Opposed the bill as a self-insured employer, saying rebates his PBM (Caremark) negotiates are returned to the plan and passed to employees; removing them would raise costs elsewhere.

Josh Sonier

Iron Workers Local 623 (health & welfare fund trustee)

HB 264

Opposed the point-of-sale rebate mandate, arguing pooled rebates benefit all covered members and a point-of-sale requirement would drain the health plan and disincentivize cheaper drugs.

Stephen Lee

Pharmacist and rare-disease (hemophilia) patient advocate

SB 401

Opposed creation of the Prescription Drug Affordability Board, fearing the board's cost data would eventually be used to restrict access to high-cost drugs for rare-disease patients.

Amanda Mitchell

Parent/patient advocate (mother of two children with complex medical needs)

SB 401

Opposed SB401, testifying that patients were not given a seat on the proposed board and that the drug-cost review process could eventually restrict access to costly medications her children rely on.

### Testified AGAINST PBMs (for reform) · against

Jeff Drozda

Louisiana Association of Health Plans

SB 401

Commended the Prescription Drug Affordability Board bill's transparency goals, citing the PBM Monitoring Advisory Council report urging Louisiana to pursue innovative drug-pricing reform frameworks.

### Hearing clips

[

![Hearing clip: LA (HB 938: Antonio Ciaccia (against)) Ohio PBM spread-pricing scandal](https://app.uslege.ai/api/clip-thumbnail/a1dfc0b1-a54a-4951-aa56-d5528e513698)▶

LA (HB 938: Antonio Ciaccia (against)) Ohio PBM spread-pricing scandal

Antonio Ciaccia, drug-pricing consultant (3 Axis Advisors / 46brooklyn Research): proponent testimony, Senate Insurance Committee · 1872-1997

“It prompted a state audit that ultimately uncovered two hundred forty-five million dollars of hidden PBM spread pricing within one year of our Ohio Medicaid program.”

Watch clip

](https://app.uslege.ai/share/a1dfc0b1-a54a-4951-aa56-d5528e513698?from=clips)

Only one clippable on-topic hearing found for this state; a second real clip was not available (no other on-topic hearing or opposition testimony).

#47 of 48

#47

## Arkansas

Most Restrictive

Arkansas enacted the most extensive, multi-law PBM reform regime of any state reviewed in its 2025 session: Act 570 (110%-of-acquisition-cost reimbursement appeal floor), Act 514 (anti-steering/ghost-network ban with up to $100,000 fines), Act 425 (Pharmacy Nondiscrimination/any-willing-pharmacy Act), Act 773 (PSAO licensure and disclosure), Act 624 (PBMs banned from holding retail pharmacy permits), Act 990 (private right of action for MAC-list violations), and Act 350 (PBM claims-payment timelines with 12% monthly penalties). This is a comprehensive, stacked reform regime enacted in a single session.

Freedom from Comprehensive Reform1/25

Few PBM Mandates2/20

Light Enforcement / No Fiduciary Duty1/20

Business-Model Freedom2/20

Limited Regulatory Reach2/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

Lee Johnson

R · Dist. 47

HB 1703

Sponsored the enacted 110%-of-acquisition-cost reimbursement law, one of several PBM bills he authored this session.

Clint Penzo

R · Dist. 31

SB 104

Sponsored both the enacted anti-steering/ghost-network law and the Pharmacy Nondiscrimination Act.

Jonathan Dismang

R · Dist. 18

SB 475

Sponsored the enacted PSAO licensure and disclosure law.

Jeremiah Moore

R · Dist. 61

HB 1150

Sponsored the enacted law banning PBMs from holding retail pharmacy permits.

**Why it matters:** Arkansas is the most heavily-regulated state in this cohort: nearly every major PBM-reform lever (pricing floors, anti-steering, PSAO licensure, ownership bans, private rights of action, claims-timing penalties) is now enacted law, leaving the debate over implementation rather than repeal.

### Bills

HB 1703Drug reimbursement process for healthcare providersRestrictive

Creates a drug reimbursement appeal process; if upheld, reimbursement must rise to at least 110% of acquisition cost and apply to that claim and future claims for the same drug.

**Sponsor:** Lee Johnson (R–47)**Status:** Enacted (Act 570)**Category:** Reimbursement floor

[View on USLege →](https://app.uslege.ai/bills/2204424)

SB 104Amend the Arkansas Pharmacy Benefits Manager Licensure ActRestrictive

Bars ghost/carve-out networks and PBM patient-steering to affiliates, requires accurate provider directories, and authorizes fines up to $100,000 per violation.

**Sponsor:** Clint Penzo (R–31)**Status:** Enacted (Act 514)**Category:** Anti-steering / network integrity

[View on USLege →](https://app.uslege.ai/bills/2204357)

SB 475Pharmacy Services Administrative Organization ActRestrictive

Requires PSAOs to be licensed by the Insurance Commissioner, imposes ownership/contract disclosure rules, and bars affiliated PSAOs from requiring pharmacies to buy solely from affiliates.

**Sponsor:** Jonathan Dismang (R–18)**Status:** Enacted (Act 773)**Category:** PSAO licensure

[View on USLege →](https://app.uslege.ai/bills/2204451)

SB 103Pharmacy Nondiscrimination ActRestrictive

Bars PBMs from excluding any licensed pharmacy willing to accept reasonable participation terms; violations trigger fines up to $100,000 and license action.

**Sponsor:** Clint Penzo (R–31)**Status:** Enacted (Act 425)**Category:** Any-willing-pharmacy

[View on USLege →](https://app.uslege.ai/bills/2204354)

HB 1150Prohibit PBM from obtaining certain pharmacy permitsRestrictive

Bars PBMs from directly or indirectly holding retail pharmacy permits, with Board of Pharmacy revocation authority and a narrow rare/orphan-drug exception.

**Sponsor:** Jeremiah Moore (R–61)**Status:** Enacted (Act 624)**Category:** PBM ownership ban

[View on USLege →](https://app.uslege.ai/bills/2204399)

HB 1531Prohibit limiting drugs to out-of-state limited distribution networksRestrictive

Restricts manufacturers from limiting drugs to out-of-state limited distribution networks and fines noncompliant manufacturers $10,000/day.

**Sponsor:** Brandon Achor (R–71)**Status:** Enacted (Act 630)**Category:** Distribution access mandate

[View on USLege →](https://app.uslege.ai/bills/2206022)

HB 1620Regulate processing and payment of PBM pharmacy claimsRestrictive

Requires clean pharmacy claims paid within 7-14 days electronically (30 days paper), imposes 12% monthly late-payment penalties, and bars PBM retaliation.

**Sponsor:** Zack Gramlich (R–50)**Status:** Enacted (Act 350)**Category:** Claims-timing mandate

[View on USLege →](https://app.uslege.ai/bills/2204439)

SB 583Amend maximum allowable cost list lawRestrictive

Creates a private right of action for pharmacies to enforce Arkansas's MAC-list law, adding compensatory/punitive damages and a $10,000-per-violation statutory remedy.

**Sponsor:** Clarke Tucker (D–14)**Status:** Enacted (Act 990)**Category:** Private right of action

[View on USLege →](https://app.uslege.ai/bills/2206133)

### Hearing clips

[

![Hearing clip: AR (SB475/Act 773: Sen. Dismang (against)) PSAOs & PBM contract loopholes](https://app.uslege.ai/api/clip-thumbnail/388f1f7c-6fc6-4fef-a271-24a42723ef3a)▶

AR (SB475/Act 773: Sen. Dismang (against)) PSAOs & PBM contract loopholes

Sen. Jonathan Dismang (R), Arkansas Senate Insurance & Commerce Cmte · 899-1021

“The PBMs know how to get around all the contracts. Well, that's a fault to the PSAOs and their inability to do what they need to do to represent our local pharmacists.”

Watch clip

](https://app.uslege.ai/share/388f1f7c-6fc6-4fef-a271-24a42723ef3a?from=clips)

Only one clippable on-topic hearing found for this state; a second real clip was not available (no other on-topic hearing or opposition testimony).

#46 of 48

#46

## Oklahoma

Most Restrictive

Oklahoma enacted a sweeping PBM-reform package: SB 773 (Patient's Right to Pharmacy Choice Act, veto OVERRIDDEN 45-0/47-0, effective Nov. 2025) bans spread pricing and discriminatory fees and arms the AG with investigatory power; SB 993 and SB 789 rewrote the Pharmacy Audit Integrity Act with tighter audit limits; HB 2048/SB 1030 (340B Nondiscrimination Act) became law. In 2026 the legislature kept pushing (SB 1447 extends PBM rebate/formulary oversight to the state employee plan, became law without signature) even as the Governor vetoed three more mandate bills (SB 2007, SB 2074, SB 1500) and SB 161 (fiduciary duty) and the rebate pass-through Act (SB 1025/HB 2817) stalled in committee.

Freedom from Comprehensive Reform2/25

Few PBM Mandates4/20

Light Enforcement / No Fiduciary Duty3/20

Business-Model Freedom2/20

Limited Regulatory Reach1/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

Todd Gollihare

R · Dist. 12

SB 773 / SB 993 / SB 1447

Chief author of Oklahoma's enacted spread-pricing ban, audit-integrity overhaul, and state-plan PBM oversight law.

Preston Stinson

R · Dist. 96

HB 2048

Chief House author of the enacted 340B Nondiscrimination Act restricting PBM reimbursement practices.

Carri Hicks

D · Dist. 40

SB 161

Sponsor of the PBM fiduciary-duty bill and companion transparency mandate SB 34.

Jonathan Wingard

R

SB 2007

Sponsor of the 2026 MAC-fee remittance mandate that passed both chambers before being vetoed.

**Why it matters:** Oklahoma has a reform-forward, veto-proof legislature: a Republican supermajority overrode the Governor to enact spread-pricing bans and AG enforcement, and is still filing new mandate bills annually even after gubernatorial vetoes.

### Bills

SB 773Patient's Right to Pharmacy Choice Act amendmentsRestrictive

Bans spread pricing and discriminatory reimbursement fees, mandates rebate/pricing transparency, and gives the Attorney General investigatory and penalty authority over PBMs.

**Sponsor:** Todd Gollihare (R–12)**Status:** Enacted (veto overridden 2025)**Category:** Spread pricing / AG enforcement

[View on USLege →](https://app.uslege.ai/bills/3264918)

SB 993Pharmacy Audit Integrity Act overhaulRestrictive

Tightens PBM audit notice, scope and timing rules, mandates appeals processes, and strengthens PBM licensing requirements.

**Sponsor:** Todd Gollihare (R–12)**Status:** Enacted (became law without signature, 2025)**Category:** Audit limits

[View on USLege →](https://app.uslege.ai/bills/3265065)

HB 2048340B Nondiscrimination ActRestrictive

Bars PBMs and insurers from discriminatory reimbursement or contract terms against 340B-covered entities, with AG/Insurance Dept. enforcement.

**Sponsor:** Preston Stinson (R–96)**Status:** Enacted (filed with Sec. of State, 2025)**Category:** 340B protections

[View on USLege →](https://app.uslege.ai/bills/3266819)

SB 1447State Employee PBM contract oversightRestrictive

Requires the state employee insurance plan's PBM contracts to pass through all rebates, bans PBM-affiliated pharmacy favoritism, and mandates audit rights and data reporting.

**Sponsor:** Todd Gollihare (R–12)**Status:** Enacted (became law without signature, 2026)**Category:** State-plan PBM oversight

[View on USLege →](https://app.uslege.ai/bills/3796346)

SB 2007PBM MAC fee remittance mandateRestrictive

Would require PBMs to remit fees when MAC reimbursements are adjusted inconsistently and sets appeal timelines; passed the legislature but was vetoed by the Governor.

**Sponsor:** Jonathan Wingard (R)**Status:** Vetoed 05/01/2026 (passed both chambers 86-3/38-1)**Category:** MAC / reimbursement mandate

[View on USLege →](https://app.uslege.ai/bills/3806811)

SB 161PBM fiduciary duty requirementRestrictive

Would impose an explicit fiduciary duty on PBMs toward insurers/enrollees and mandate detailed AG reporting; did not advance past General Order.

**Sponsor:** Carri Hicks (D–40)**Status:** Stalled (Placed on General Order, no further action)**Category:** Fiduciary duty

[View on USLege →](https://app.uslege.ai/bills/3264136)

SB 1025Rebate Pass-Through and PBM Meaningful Transparency ActRestrictive

Would mandate PBM licensure, 85% rebate pass-through at point of sale, spread-pricing bans, and P&T committee transparency; failed to advance.

**Sponsor:** John Haste (R)**Status:** Stalled (2025, referred to committee)**Category:** Rebate pass-through

[View on USLege →](https://app.uslege.ai/bills/2173013)

### Hearing clips

[

![Hearing clip: OK (SB 773: AG Gentner Drummond (against)) PBM Enforcement Unit Results](https://app.uslege.ai/api/clip-thumbnail/fd0b95a9-b34b-41c8-90ab-2db22b54d77a)▶

OK (SB 773: AG Gentner Drummond (against)) PBM Enforcement Unit Results

Attorney General Gentner Drummond · 584-752

“I'm thrilled with the success of the PBM unit after years of inaction against corrupt practices from a number of pharmacy benefit managers.”

Watch clip

](https://app.uslege.ai/share/fd0b95a9-b34b-41c8-90ab-2db22b54d77a?from=clips)

Only one clippable on-topic hearing found for this state; a second real clip was not available (no other on-topic hearing or opposition testimony).

#45 of 48

#45

## Indiana

Most Restrictive

Indiana enacted three separate comprehensive PBM-hostile laws in a single session: SB 3 (Public Law 69) imposes a fiduciary duty on PBMs/TPAs toward plan sponsors with full fee/conflict disclosure; SB 140 (Public Law 189) is a full PBM regulatory framework covering network adequacy, reimbursement practices, a ban on retroactive claim denials, and Insurance Commissioner oversight; HB 1604 (Public Law 237) adds cost-sharing mandates plus new PBM licensing/regulatory requirements effective 2026. All three are law, not pending.

Freedom from Comprehensive Reform2/25

Few PBM Mandates3/20

Light Enforcement / No Fiduciary Duty3/20

Business-Model Freedom2/20

Limited Regulatory Reach2/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

Ed Charbonneau

R

SB 140

Lead author of the enacted comprehensive PBM regulatory framework.

Justin Busch

R

SB 3

Lead author of the enacted PBM/TPA fiduciary-duty law.

Julie McGuire

R

HB 1604

Lead author of the enacted cost-sharing mandate and PBM licensing requirement.

**Why it matters:** Indiana is now one of the most heavily-regulated states in USLege's coverage: three stacked, enacted comprehensive statutes (fiduciary duty, full PBM licensing/oversight, and cost-sharing mandates) leave essentially no light-touch space for PBMs operating there, and all three passed with Republican authorship, undercutting any assumption that a GOP trifecta preserves a light-touch PBM model.

### Bills

SB 140Pharmacy benefitsRestrictive

Establishes a full regulatory chapter for PBMs covering network adequacy, reimbursement practices, a prohibition on retroactive claim denials, anti-discrimination protections for pharmacies, transparency, complaint procedures, and Insurance Commissioner oversight.

**Sponsor:** Ed Charbonneau (R)**Status:** Enacted: Public Law 189 (2025)**Category:** Comprehensive PBM regulation

[View on USLege →](https://app.uslege.ai/bills/2034830)

SB 3Fiduciary duty in health plan administrationRestrictive

Establishes a fiduciary duty for third-party administrators and PBMs acting on behalf of health plan sponsors, requiring loyalty, care, full disclosure of fees/costs, avoidance of conflicts of interest, and transparency in financial/contractual arrangements including prescription drug benefits.

**Sponsor:** Justin Busch (R)**Status:** Enacted: Public Law 69 (2025)**Category:** Fiduciary duty

[View on USLege →](https://app.uslege.ai/bills/2034691)

HB 1604Cost sharing; out-of-pocket expense creditRestrictive

Requires insurers and PBMs to apply federal cost-sharing limitations and count all cost-sharing payments (including manufacturer assistance) toward deductibles/out-of-pocket maximums, and introduces new PBM licensing and regulatory-oversight requirements effective January 1, 2026.

**Sponsor:** Julie McGuire (R)**Status:** Enacted: Public Law 237 (2025)**Category:** Cost-sharing mandate & PBM licensing

[View on USLege →](https://app.uslege.ai/bills/2034359)

### Who testified: stakeholders on the record · 8 on the record

### Testified FOR PBMs (against new regulation) · for

No witnesses testified in support on the record.

### Testified AGAINST PBMs (for reform) · against

Matt Bell

Hoosiers for Affordable Health Care

SB3

Supported the fiduciary-duty bill requiring TPAs/PBMs to act loyally in the plan sponsor's best interest, saying it builds confidence that benefit plans aren't steered by third-party financial relationships.

Gloria Sachdev

Secretary, Indiana Family and Social Services Administration / Health & Family Services (Gov. Braun's office)

SB3

Testified this is a governor's-priority bill; PBMs/TPAs should be fiduciaries so formularies are built on net cost rather than rebate size.

Dave Kelleher

Employers Forum of Indiana

SB3

Advocated for accountability/fairness in healthcare, arguing employers face unsustainable costs partly from PBM/TPA conflicts of interest that a fiduciary duty would address.

Josh Archambault

Cicero Action

HB1604

Supported the out-of-pocket cost-sharing credit mandate requiring insurers/PBMs to count patients' direct cash-pay prices toward their deductible.

Matt Bell

Hoosiers for Affordable Health Care

HB1604

"Proud to stand in support" of the bill empowering Hoosiers to shop for lower prices and get deductible credit.

Ashton Eller

Indiana Manufacturers Association

HB1604

Supported the consumer cost-sharing-credit provisions but opposed extending the mandate to ERISA self-funded plans as state overreach into plan design.

Natalie Robinson

NFIB Indiana

HB1604

Expressed support for the bill as encouraging cost-conscious healthcare shopping, requesting implementation support/guidance for small self-insured employers.

Gloria Sachdev

Secretary, Indiana Family and Social Services Administration / Health & Family Services

HB1604

Cited real-world direct-pay lab-testing price examples in strong support of the cost-sharing credit mandate.

### Hearing clips

[

![Hearing clip: IN (SB 140: Phil Christofanelli, PCMA (for)) opposes broad PBM redefinition amendment](https://app.uslege.ai/api/clip-thumbnail/f60bf350-5421-4141-be39-d9d8dcf1bea2)▶

IN (SB 140: Phil Christofanelli, PCMA (for)) opposes broad PBM redefinition amendment

Phil Christofanelli, Pharmaceutical Care Management Association (PCMA) · 22:03-24:03

“I represent the Pharmaceutical Care Management Association, which is the national trade association representing all of the nation's PBMs... I'm here to testify now in opposition to your amended bill.”

Watch clip

](https://app.uslege.ai/share/f60bf350-5421-4141-be39-d9d8dcf1bea2?from=clips)[

![Hearing clip: IN (SB 140: Rep. Julie McGuire (against)) carries PBM fair-reimbursement bill in conference report](https://app.uslege.ai/api/clip-thumbnail/440e7867-f95f-49b7-8ca8-e83e97bb9299)▶

IN (SB 140: Rep. Julie McGuire (against)) carries PBM fair-reimbursement bill in conference report

Rep. Julie McGuire · 67:59-68:39

“Senate bill 140 is our pharmacy benefit manager bill this year. It's an effort to bring fair pharmacy reimbursement to our independents and also to preserve patient choice and access to the pharmacies of their choosing.”

Watch clip

](https://app.uslege.ai/share/440e7867-f95f-49b7-8ca8-e83e97bb9299?from=clips)

#44 of 48

#44

## Colorado

Most Restrictive

Colorado enacted the nation's most aggressive PBM reform stack this cycle: HB25-1094 bans PBM income tied to drug prices and mandates transparency, HB25-1222 sets mandatory rural-pharmacy reimbursement floors with audit-appeal rights, and SB26-167 forces a copay-accumulator ban counting manufacturer assistance toward patient out-of-pocket maximums. A further PBM transparency/sourcing bill (HB26-1056) and a PDAB-exemption rollback attempt (SB26-140) both failed in committee, but the enacted framework alone marks CO as reform-forward, not industry-friendly.

Freedom from Comprehensive Reform2/25

Few PBM Mandates3/20

Light Enforcement / No Fiduciary Duty3/20

Business-Model Freedom2/20

Limited Regulatory Reach2/15

### Favor light-touch regulation · PBM-friendly

Lisa Frizell

R

SB 26-140

Sponsored a bill exempting rare-disease/biologic drugs from PDAB affordability review, narrowing regulatory reach (failed in House committee).

### Favor PBM reform · reform-forward

Kyle Brown

D

HB 25-1094

Sponsored the enacted law banning PBM income tied to drug prices and mandating transparency.

Meghan Lukens

D

HB 25-1222

Sponsored the enacted law mandating minimum PBM reimbursement/dispensing fees and audit-appeal rights.

Adrienne Benavidez

D

SB 26-167

Sponsored the enacted copay-accumulator ban forcing PBMs/carriers to count manufacturer assistance toward out-of-pocket maximums.

Ken DeGraaf

R

HB 26-1056

Sponsored a PBM cost-transparency disclosure mandate (failed in committee).

**Why it matters:** Colorado is now one of the most heavily-regulated operating environments for PBMs: income restrictions, mandated reimbursement floors, and a copay-accumulator ban directly compress PBM margin levers and require operational overhauls to stay compliant.

### Bills

HB 25-1094Pharmacy Benefit Manager PracticesRestrictive

Establishes regulations on PBMs regarding assessment of service fees, income sources, reimbursement methods, formulary design, and transparency in prescription drug costs. Prohibits PBMs from earning income based on drug prices and mandates fair reimbursement and disclosure practices.

**Sponsor:** Kyle Brown (D)**Status:** Governor Signed (2025-05-30)**Category:** Comprehensive PBM reform

[View on USLege →](https://app.uslege.ai/bills/2305931)

HB 25-1222Preserving Access to Rural Independent PharmaciesRestrictive

Defines rural independent pharmacies and restricts certain PBM practices; mandates minimum reimbursement rates and dispensing fees, requires fair audit and appeal procedures, and allows remote pharmacist review to sustain rural pharmacy access.

**Sponsor:** Meghan Lukens (D)**Status:** Governor Signed (2025-05-27)**Category:** Reimbursement mandate / audit-appeal

[View on USLege →](https://app.uslege.ai/bills/2305997)

SB 26-167Prescription Drug Out-of-Pocket Expense CreditRestrictive

Starting 2028, requires carriers to count out-of-pocket expenses paid directly by covered individuals for prescription drugs toward out-of-pocket maximums or cost-sharing requirements, subject to verification and in-network pricing limits.

**Sponsor:** Adrienne Benavidez (D)**Status:** Governor Signed (2026-06-03)**Category:** Copay-accumulator ban

[View on USLege →](https://app.uslege.ai/bills/3874749)

HB 26-1056Prescription Drug Benefit Information TransparencyRestrictive

The Prescription Drug Optimized Sourcing Transparency and Integrity Act would have protected self-insured employers' lawful alternative sourcing programs, prohibited PBMs from disseminating false information about them, and mandated PBM disclosure of detailed drug cost information on request.

**Sponsor:** Ken DeGraaf (R)**Status:** House Committee Postponed Indefinitely / failed (2026-02-17)**Category:** PBM transparency mandate (failed)

[View on USLege →](https://app.uslege.ai/bills/3806141)

SB 26-140Exempt Drugs from Prescription Drug Affordability Board ReviewsEnabling

Would have exempted FDA-designated rare-disease drugs and human-plasma-derived biological products from affordability review and upper payment limit regulation by Colorado's Prescription Drug Affordability Review Board.

**Sponsor:** Lisa Frizell (R)**Status:** House Committee Postponed Indefinitely / failed (2026-04-22)**Category:** PDAB exemption / deregulation (failed)

[View on USLege →](https://app.uslege.ai/bills/3865176)

### Hearing clips

No clip available. Colorado's legislative video is copyrighted or restricted by state law. No on-topic PBM hearing exists on the record for HB 25-1094 in any case: only floor days and Medical Services Board meetings that touch the word 'benefit' incidentally.

#43 of 48

#43

## Vermont

Most Restrictive

Vermont enacted a cluster of drug-pricing and PBM-facing measures in the 2025–2026 biennium: H.266 (340B non-interference bar on manufacturers plus outpatient drug charge caps tied to ASP), H.611 (expanded drug-cost transparency reporting and 340B data-sharing protections), and H.577 (state-run discount-card program that forces PBMs/insurers to count discount-card payments toward enrollee deductibles). A further PBM-pharmacy ownership ban (H.156) and a NADAC-plus-dispensing-fee patient cost cap with insurer disclosure mandates (H.202) remain pending in committee, signaling more reform is queued up.

Freedom from Comprehensive Reform3/25

Few PBM Mandates3/20

Light Enforcement / No Fiduciary Duty2/20

Business-Model Freedom2/20

Limited Regulatory Reach3/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

Alyssa Black

Democratic

H.266

Sponsored the enacted 340B protection and drug-charge-cap law, and also H.577's PBM deductible-counting mandate.

Daisy Berbeco

Democratic

H.611

Sponsored the enacted drug-cost transparency expansion affecting PBM/manufacturer data disclosure.

Mari Cordes

Democratic

H.156

Sponsored the pending PBM-pharmacy ownership ban and the NADAC-based patient cost-cap transparency bill (H.202).

**Why it matters:** Vermont is a top-tier reform state: three PBM/drug-pricing bills have already become law this biennium, and the pending ownership ban (H.156) plus the NADAC-based patient cost-cap bill (H.202) represent the next likely wave of restriction if either advances.

### Bills

H.266340B prescription drug pricing programRestrictive

Bars manufacturers from interfering with 340B contract-pharmacy drug acquisition or from substituting rebates for point-of-purchase discounts, creates a private right of action for violations, mandates hospital 340B reporting to the Green Mountain Care Board, and caps outpatient/office-administered drug charges tied to ASP starting January 2026.

**Sponsor:** Alyssa Black (Democratic)**Status:** Enacted: Governor approved June 11, 2025**Category:** 340B protection / drug charge caps

[View on USLege →](https://app.uslege.ai/bills/2322458)

H.611Miscellaneous provisions affecting the Department of Vermont Health AccessRestrictive

Expands prescription drug cost-transparency reporting duties for insurers and manufacturers and bars certain data-sharing restrictions tied to 340B drug pricing, alongside broader Medicaid program changes.

**Sponsor:** Daisy Berbeco (Democratic)**Status:** Enacted: Governor signed June 8, 2026**Category:** Drug-cost transparency

[View on USLege →](https://app.uslege.ai/bills/3796296)

H.577Vermont Prescription Drug Discount Card ProgramRestrictive

Creates a state-run prescription discount-card program and requires health insurers and PBMs to count discount-card payments toward enrollee deductibles and out-of-pocket limits, even for drugs bought outside the plan.

**Sponsor:** Alyssa Black (Democratic)**Status:** Enacted: Governor signed June 15, 2026**Category:** Deductible / cost-sharing mandate on PBMs

[View on USLege →](https://app.uslege.ai/bills/3789855)

H.156Prohibiting PBMs from owning or operating a pharmacy in VermontRestrictive

Would prohibit pharmacy benefit managers from owning or operating pharmacies in Vermont, separating PBM and pharmacy roles to prevent conflicts of interest and protect independent pharmacies.

**Sponsor:** Mari Cordes (Democratic)**Status:** Introduced, referred to Health Care Committee: no further action (2025)**Category:** PBM-pharmacy ownership ban

[View on USLege →](https://app.uslege.ai/bills/2322344)

H.202Increasing transparency of prescription drug costs and spendingRestrictive

Would cap patient out-of-pocket drug costs at NADAC plus a professional dispensing fee, require pharmacies to disclose pricing options, and mandate insurer disclosure of annual per-enrollee drug spending.

**Sponsor:** Mari Cordes (Democratic)**Status:** Introduced, referred to Health Care Committee: no further action (2025)**Category:** Reimbursement cap / transparency

[View on USLege →](https://app.uslege.ai/bills/2322394)

### Hearing clips

No clip available. No clearly attributed witness testimony, for or against, exists on Vermont's core PBM bills (H.266, H.611, H.577, H.156, H.202). The House Health Care, Senate Health and Welfare, Senate Finance, House Ways and Means and House Appropriations records hold only technical bill-language walkthroughs by legislative counsel, a state-employee-benefits official describing Vermont's own OptumRx contract, and a brief unattributed legislator aside about PBM 'middlemen'.

#42 of 48

#42

## Rhode Island

Most Restrictive

Rhode Island enacted two comprehensive PBM laws in June 2026, both signed by the Governor: the PBM Act (SB 3060/HB 8579) requires PBMs to obtain a certificate of authority from the health insurance commissioner and empowers the commissioner to penalize violations, and the Pharmacy Freedom of Choice -- Fair Competition and Practices Act (SB 3059/HB 8582) imposes duties, transparency, and accountability on PBMs and bars anti-steering practices. Several follow-on bills (spread-pricing monitoring SB 2462, Rx Drug Savings and Transparency Act SB 2563, fair-reimbursement companion SB 2466) were held for further study, suggesting more reform is queued for next session.

Freedom from Comprehensive Reform3/25

Few PBM Mandates3/20

Light Enforcement / No Fiduciary Duty3/20

Business-Model Freedom2/20

Limited Regulatory Reach2/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

Robert Britto

D · Dist. 18

SB 3059

Sponsor of the enacted Pharmacy Freedom of Choice anti-steering/fair-competition law.

Peter Apollonio

D

SB 3060

Sponsor of the enacted PBM Act requiring certificate-of-authority licensure.

Linda Ujifusa

D

SB 2563 / SB 2462

Sponsor of the pending Rx Drug Savings and Transparency Act and the spread-pricing monitoring mandate queued for next session.

**Why it matters:** Rhode Island is newly and comprehensively regulated: PBMs must now hold a state certificate of authority and comply with anti-steering/fair-competition duties enforceable by the insurance commissioner, with additional spread-pricing and transparency bills already drafted for a future session.

### Bills

SB 3060Pharmacy Benefit Managers ActRestrictive

Requires PBMs to obtain a certificate of authority from the Office of the Health Insurance Commissioner and empowers the commissioner to oversee PBMs and penalize violations.

**Sponsor:** Peter Apollonio (D)**Status:** Signed by Governor, June 2026**Category:** Licensure

[View on USLege →](https://app.uslege.ai/bills/3887560)

HB 8579Pharmacy Benefit Managers Act (House companion)Restrictive

House companion requiring PBM certificate-of-authority licensure through DBR with commissioner oversight and penalty authority.

**Sponsor:** Tina Spears (D)**Status:** Signed by Governor, June 2026**Category:** Licensure

[View on USLege →](https://app.uslege.ai/bills/3882792)

SB 3059Pharmacy Freedom of Choice -- Fair Competition and PracticesRestrictive

Imposes duties, transparency, and accountability requirements on PBMs and pharmacy benefits management services, targeting patient-steering practices.

**Sponsor:** Robert Britto (D–18)**Status:** Signed by Governor, June 2026**Category:** Anti-steering / transparency

[View on USLege →](https://app.uslege.ai/bills/3887559)

HB 8582Pharmacy Freedom of Choice (House companion)Restrictive

House companion imposing fair-competition duties and anti-steering protections on PBMs.

**Sponsor:** Justine Caldwell (D–30)**Status:** Signed by Governor, June 2026**Category:** Anti-steering / transparency

[View on USLege →](https://app.uslege.ai/bills/3883032)

SB 2563Prescription Drug Savings and Transparency Act of 2026Restrictive

Would establish a broader prescription drug savings and transparency framework; held for further study rather than advanced this session.

**Sponsor:** Linda Ujifusa (D)**Status:** Passed Senate 34-0, referred to House Finance, May 2026 (actively advancing)**Category:** Transparency

[View on USLege →](https://app.uslege.ai/bills/3887063)

SB 2462Spread-pricing monitoring mandateRestrictive

Requires the state health and human services office to monitor and mandate changes to PBM price-setting to prohibit spread pricing.

**Sponsor:** Linda Ujifusa (D)**Status:** Referred to House Finance, April 2026**Category:** Spread pricing

[View on USLege →](https://app.uslege.ai/bills/3886962)

### Who testified: stakeholders on the record · 1 on the record

### Testified FOR PBMs (against new regulation) · for

Sam Hollemeier

Pharmaceutical Care Management Association (PCMA)

SB 3059 / SB 3060 (PBM Act & Pharmacy Freedom of Choice)

Testified in opposition to both PBM licensure/certificate-of-authority bills, arguing PBMs already lower drug costs, that hiring a PBM is optional, and that the bills grant the DBR director overly broad rulemaking authority beyond legislative intent.

### Testified AGAINST PBMs (for reform) · against

No witnesses testified in opposition on the record.

### Hearing clips

[

![Hearing clip: RI (PBM pharmacy reimbursement bill: Rep. Kislak (against)) pharmacies reimbursed below cost](https://app.uslege.ai/api/clip-thumbnail/07125a68-d1cc-4ee8-84f7-1d03a1231782)▶

RI (PBM pharmacy reimbursement bill: Rep. Kislak (against)) pharmacies reimbursed below cost

Rep. Rebecca Kislak (RI House) · 1788-1910

“That's ridiculous. That's no way to run a business. And we should put some guardrails up to make sure that pharmacies can be reimbursed at least the cost to them for providing the medication.”

Watch clip

](https://app.uslege.ai/share/07125a68-d1cc-4ee8-84f7-1d03a1231782?from=clips)

Only one clippable on-topic hearing found for this state; a second real clip was not available (no other on-topic hearing or opposition testimony).

#41 of 48

#41

## North Carolina

Most Restrictive

NC enacted the SCRIPT Act (SB 479, Ch. SL 2025-69) this session: a comprehensive PBM/PSAO regime covering pharmacy-choice protection, PSAO licensure, below-cost reimbursement bans, audit-protection strengthening, and rebate/drug-pricing transparency, phasing in through 2027. HB 163 (PBM Provisions: spread-pricing ban, specialty-pharmacy accreditation standards, audit protections) has crossed to the Senate and remains live. SB 287 would bar PBM/insurer utilization review from relying solely on AI algorithms to deny care.

Freedom from Comprehensive Reform2/25

Few PBM Mandates3/20

Light Enforcement / No Fiduciary Duty3/20

Business-Model Freedom3/20

Limited Regulatory Reach3/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

Benton Sawrey

R · Dist. 10

SB 479

Chief sponsor of the enacted SCRIPT Act, NC's comprehensive PBM/PSAO reform law.

Heather Rhyne

R · Dist. 97

HB 163

Sponsors a second-layer spread-pricing ban and audit-protection bill advancing in the Senate.

Gale Adcock

D · Dist. 16

SB 287

Sponsors bill restricting PBM/insurer AI-driven utilization-review denials.

**Why it matters:** NC is now a marquee reform state: the enacted SCRIPT Act is a template other legislatures may copy, and HB 163 would add a second layer of spread-pricing and audit restrictions on top of it.

### Bills

SB 479SCRIPT ActRestrictive

Establishes pharmacy-choice protections, PSAO licensure/disclosure, bans below-cost reimbursement, strengthens audit protections, and increases reporting/transparency on drug pricing, rebate distribution, and PBM contracts.

**Sponsor:** Benton Sawrey (R–10)**Status:** Ch. SL 2025-69 (enacted), effective dates through 2027**Category:** Comprehensive PBM/PSAO reform

[View on USLege →](https://app.uslege.ai/bills/2087830)

HB 163Pharmacy Benefits Manager ProvisionsRestrictive

Prohibits spread pricing, regulates PBM fees/rebates (concessions), guarantees patient pharmacy choice, sets uniform specialty-pharmacy accreditation standards, and strengthens pharmacy audit protections with mandated PBM reporting.

**Sponsor:** Heather Rhyne (R–97)**Status:** Passed House, Ref to Com On Rules and Operations of the Senate (pending), 2025-26 session**Category:** Spread-pricing ban / audit protections

[View on USLege →](https://app.uslege.ai/bills/2086509)

HB 736Pharmacists/Test and TreatRestrictive

Mandates health insurers reimburse pharmacist-provided testing/treatment services (flu, COVID, strep) equivalent to other providers, expanding mandated-coverage obligations insurers/PBMs must administer.

**Sponsor:** Cody Huneycutt (R)**Status:** Ref to Com On Health (pending), 2025-26 session**Category:** Pharmacist reimbursement parity

[View on USLege →](https://app.uslege.ai/bills/2087152)

SB 287Safeguard Health Ins. Utilization ReviewsRestrictive

Bars insurers/PBMs from using AI algorithms as the sole basis for utilization-review denials; requires licensed clinicians to make medical-necessity determinations.

**Sponsor:** Gale Adcock (D–16)**Status:** Ref to Com On Rules and Operations of the Senate (pending), 2025-26 session**Category:** Utilization-management restriction

[View on USLege →](https://app.uslege.ai/bills/2087644)

### Hearing clips

No clip available. No on-topic committee hearing exists for North Carolina's PBM bills (SB 479, HB 163). The state's available legislative video is dominated by county and municipal meetings and general House floor sessions, with no PBM-specific hearing on record.

#40 of 48

#40

## Alaska

Most Restrictive

Alaska enacted SB132, an omnibus insurance bill that builds a comprehensive PBM/third-party-administrator licensing, examination, and reporting framework under the Division of Insurance (already law, effective date per chapter). Companion measures SB134/HB149 create standalone PBM/TPA licensure requirements and SB142 extends the same PBM regulatory framework to municipal and state self-insured group health plans: a broad, session-long push to bring PBMs fully under state insurance oversight.

Freedom from Comprehensive Reform3/25

Few PBM Mandates3/20

Light Enforcement / No Fiduciary Duty3/20

Business-Model Freedom3/20

Limited Regulatory Reach2/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

Cathy Giessel

R · Dist. 5

SB 134

Sponsored both the standalone PBM/TPA licensure bill and the bill extending PBM regulation to public self-insured plans.

**Why it matters:** Alaska is a newly-hardened reform state: the licensing/examination regime is enacted law, and pending bills (SB134/HB149, SB142) would extend the same oversight to self-insured government plans that PBMs currently service with less friction.

### Bills

SB 132Omnibus Insurance BillRestrictive

Introduces comprehensive regulatory provisions for PBMs and TPAs, expanding the insurance director's authority to license, examine, and require detailed reporting and contracts to enhance oversight and consumer protections.

**Sponsor:** Senate Labor & Commerce Committee**Status:** Enacted (effective date per chapter)**Category:** Comprehensive PBM/TPA licensure

[View on USLege →](https://app.uslege.ai/bills/2330867)

SB 134Pharmacy Benefits Manager; 3rd Party AdminRestrictive

Establishes comprehensive licensing, examination, and regulatory requirements for PBMs and TPAs, including financial/operational oversight and contract standards between insurers and PBMs/TPAs.

**Sponsor:** Cathy Giessel (R–5)**Status:** Referred to House Rules**Category:** Licensure

[View on USLege →](https://app.uslege.ai/bills/2330877)

HB 149Pharmacy Benefits Manager; 3rd Party AdminRestrictive

House companion establishing licensure, examination, and reporting requirements for PBMs and TPAs, bringing them under the insurance director's regulatory authority.

**Sponsor:** House Labor & Commerce Committee**Status:** Referred to Health & Social Services**Category:** Licensure

[View on USLege →](https://app.uslege.ai/bills/2330612)

SB 142Health Insurance & Pharmacy Benefits ManagersRestrictive

Extends existing PBM regulatory requirements to municipal and state group health insurance plans, including self-insured plans, excluding ERISA plans, effective January 1, 2026.

**Sponsor:** Cathy Giessel (R–5)**Status:** Referred to Labor & Commerce**Category:** Scope expansion to public plans

[View on USLege →](https://app.uslege.ai/bills/2330873)

### Hearing clips

No clip available. Alaska has a strongly on-topic Senate Health & Social Services hearing (board-of-pharmacy nominee testimony on PBM access barriers) but Alaska's legislative media is copyrighted or restricted by state law, so no clip can be created from it regardless of content.

#39 of 48

#39

## California

Most Restrictive

California enacted SB41 (Chapter 605, Statutes of 2025), a comprehensive PBM law requiring licensure, mandatory pass-through pricing, a spread-pricing ban, capping PBM income to management fees, and barring discrimination against non-affiliated pharmacies. The 2026 session continues expanding the regime: AB577 (antisteering on injected/infused drugs), SB1094 (bars PBM-affiliate steering on biosimilars), SB1244 (compensation-disclosure for benefits intermediaries, advancing 12-0 in committee), and AB1773 (public PBM licensing-status website).

Freedom from Comprehensive Reform2/25

Few PBM Mandates3/20

Light Enforcement / No Fiduciary Duty3/20

Business-Model Freedom4/20

Limited Regulatory Reach3/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

Scott Wiener

D · Dist. 11

SB 41

Sponsored the enacted comprehensive PBM licensure, pass-through pricing, and spread-pricing-ban law.

Lori D. Wilson

D · Dist. 11

AB 577

Sponsored the pending antisteering bill covering injected/infused/oral medications.

Benjamin Allen

D · Dist. 24

SB 1244

Sponsored the advancing benefits-intermediary compensation-disclosure act.

Akilah Weber Pierson

D · Dist. 39

SB 1094

Sponsored the bill barring PBM-affiliate steering on biosimilar substitution.

**Why it matters:** California is a fully hardened reform state: SB41 already caps PBM compensation and bans spread pricing in law, and the pipeline of 2026 bills (SB1094, SB1244, AB577) shows the Legislature actively closing remaining gaps rather than reconsidering the framework.

### Bills

SB 41Pharmacy benefitsRestrictive

Requires PBM licensure, mandates pass-through pricing, limits PBM income to management fees, prohibits spread pricing and preferential treatment of affiliated pharmacies, and authorizes civil and criminal enforcement.

**Sponsor:** Scott Wiener (D–11)**Status:** Chaptered: Ch. 605, Statutes of 2025**Category:** Comprehensive licensure / spread-pricing ban

[View on USLege →](https://app.uslege.ai/bills/2018573)

AB 577Health care coverage: antisteeringRestrictive

Bars health plans, insurers, and PBMs from steering patients away from medically necessary administration settings/providers for injected, infused, and oral medications; requires cost-sharing disclosure.

**Sponsor:** Lori D. Wilson (D–11)**Status:** Died Feb 2, 2026 (2-year bill; failed to clear house of origin)**Category:** Anti-steering

[View on USLege →](https://app.uslege.ai/bills/2017415)

AB 1773Pharmacy benefit managersRestrictive

Requires the Department of Managed Health Care to maintain a public website listing PBM licensing details (name, license number, issuance/expiration dates).

**Sponsor:** Blanca E. Rubio (D–48)**Status:** Hearing canceled at author's request**Category:** Licensing transparency

[View on USLege →](https://app.uslege.ai/bills/3843639)

SB 1094Prescription drugsRestrictive

Sets conditions for biosimilar substitution/switching and bars PBMs, plans, and insurers from requiring only an affiliated biosimilar when unaffiliated options are available.

**Sponsor:** Akilah Weber Pierson (D–39)**Status:** Read second time, amended, re-referred to Appropriations**Category:** Biosimilar anti-steering

[View on USLege →](https://app.uslege.ai/bills/3849872)

SB 1244Public Agency Benefits Intermediary Compensation Disclosure ActRestrictive

Requires brokers, agents, consultants, and advisors serving public-agency health benefits to disclose all direct and indirect compensation before contracting and annually thereafter.

**Sponsor:** Benjamin Allen (D–24)**Status:** Do pass, re-referred to Appropriations (12-0)**Category:** Compensation transparency

[View on USLege →](https://app.uslege.ai/bills/3852684)

AB 2000Drug formulariesRestrictive

Restricts mid-year formulary changes by health plans/insurers, requires enrollee notice, and protects continued access to previously-covered drugs.

**Sponsor:** Cecilia Aguiar-Curry (D)**Status:** Held under submission**Category:** Formulary stability mandate

[View on USLege →](https://app.uslege.ai/bills/3849821)

### Who testified: stakeholders on the record · 2 on the record

### Testified FOR PBMs (against new regulation) · for

No witnesses testified in support on the record.

### Testified AGAINST PBMs (for reform) · against

Omar Altamimi

California Pan-Ethnic Health Network (CPAN)

SB 41

Testified in support of the PBM budget-trailer proposals implementing SB41's PBM licensure/spread-pricing reforms at an Assembly budget subcommittee hearing on the Department of Managed Health Care's PBM oversight funding.

Katie Van Deynze

Health Access California

SB 41

Testified in support of SB41 (and companion SB306) at a Senate budget subcommittee hearing, backing the bill's PBM licensure mandate, spread-pricing ban, and rebate pass-through requirements.

### Hearing clips

[

![Hearing clip: CA (SB41: Sen. Wiener (against)) PBMs "corporate behemoths"](https://app.uslege.ai/api/clip-thumbnail/50b1cbb6-298e-4fcf-97d8-20c28be0df2e)▶

CA (SB41: Sen. Wiener (against)) PBMs "corporate behemoths"

Sen. Scott Wiener (D), CA Senate Health Committee · 9094-9422

“PBMs have grown into massive, massive corporations, often larger than the health plans... corporate behemoths that play a very, very powerful role, I think sometimes unduly powerful, within the health care systems.”

Watch clip

](https://app.uslege.ai/share/50b1cbb6-298e-4fcf-97d8-20c28be0df2e?from=clips)[

![Hearing clip: CA (SB41: Ike Brannan/PCMA (for)) "blame the middleman perspective isn't true"](https://app.uslege.ai/api/clip-thumbnail/9bd969b2-8b48-456a-b824-45df5d3225df)▶

CA (SB41: Ike Brannan/PCMA (for)) "blame the middleman perspective isn't true"

Ike Brannan, economist, Kemp Foundation (testifying for PCMA in opposition to SB41) · 10006-10133

“This blame-the-middleman perspective isn't true... PBMs provide considerable value by negotiating lower prices and managing drug formularies on behalf of health care plans.”

Watch clip

](https://app.uslege.ai/share/9bd969b2-8b48-456a-b824-45df5d3225df?from=clips)

#38 of 48

#38

## Tennessee

Most Restrictive

Tennessee is one of the most aggressive PBM-reform states in the country. The enacted FAIR Rx Act (HB 1959/SB 2040, 2026) bans PBM/insurer ownership of pharmacies statewide from July 2028, and enacted HB 1244/SB 881 (2025) imposes prompt-payment penalties on PBMs. Stacked on top, a 2026 bill slate: SB 2576/HB 2332 (NADAC/WAC-based minimum reimbursement + appeal process), SB 2574/HB 2333 (prescriber-authority protections, timelines, transparency reporting), HB 2331/SB 2577 (bars state contracts with disciplined PBMs), and SB 1796/HB 1955 (annual public PBM-violation reporting): is actively advancing through committee. This is a comprehensive, multi-front reform regime, not an isolated bill.

Freedom from Comprehensive Reform3/25

Few PBM Mandates4/20

Light Enforcement / No Fiduciary Duty3/20

Business-Model Freedom3/20

Limited Regulatory Reach3/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

Rick Scarbrough

Republican · Dist. 33

HB 1959

Sponsored the enacted FAIR Rx Act banning PBM ownership of pharmacies statewide.

Brock Martin

Republican · Dist. 79

HB 1244

Sponsored the enacted prompt-payment law subjecting PBMs to reimbursement-timing penalties.

Bobby Harshbarger

Republican · Dist. 4

SB 2576

Sponsored the NADAC/WAC-based minimum reimbursement and MAC-appeal bill advancing through committee.

Ed Butler

Republican · Dist. 41

HB 2331

Sponsored the bill barring state contracts with PBMs found to have violated PBM regulations.

Shane Reeves

Republican · Dist. 14

SB 1796

Sponsored the bill requiring annual public reporting of PBM regulatory violations.

**Why it matters:** Tennessee is a top-tier reform state: the enacted ownership ban and prompt-payment law are already binding, and the pending reimbursement-floor and transparency package would layer mandated NADAC-based pay floors and public violation reporting on top if it advances.

### Bills

HB 1959FAIR Rx Act: PBM/insurer ownership of pharmaciesRestrictive

Prohibits PBMs, health insurance issuers, or their affiliates from owning, operating, or controlling any pharmacy in Tennessee starting July 1, 2028, to eliminate the conflict of interest of PBM-owned pharmacies and protect independent/rural pharmacy access.

**Sponsor:** Rick Scarbrough (Republican–33)**Status:** Enacted: Pub. Ch. 1111 (2026)**Category:** PBM-pharmacy ownership ban

[View on USLege →](https://app.uslege.ai/bills/3818884)

HB 1244Timely reimbursement requirements for pharmacy benefits managersRestrictive

Subjects PBMs to existing prompt-payment statutes and regulatory sanctions, enforcing timely reimbursement of pharmacy claims with corresponding penalties for late payment.

**Sponsor:** Brock Martin (Republican–79)**Status:** Enacted: Pub. Ch. 446 (2025)**Category:** Prompt-payment enforcement

[View on USLege →](https://app.uslege.ai/bills/2065578)

SB 2576Minimum reimbursement standards for PBMsRestrictive

Mandates minimum PBM reimbursement to pharmacies based on actual acquisition cost, NADAC, or WAC, creates a pharmacy appeal process for underpayment, and requires timely payment of dispensing fees without cost pass-through to patients, effective July 1, 2026 if enacted.

**Sponsor:** Bobby Harshbarger (Republican–4)**Status:** In committee: assigned to Senate Commerce & Labor General Subcommittee (2026)**Category:** Reimbursement floor / MAC appeal

[View on USLege →](https://app.uslege.ai/bills/3843316)

SB 2574Prescriber authority and PBM transparency requirementsRestrictive

Bars PBMs from overriding prescriber medication decisions, sets prior-authorization response timelines, prohibits retaliation against prescribers/pharmacies, and mandates annual transparency reporting to state regulators.

**Sponsor:** Bobby Harshbarger (Republican–4)**Status:** In committee: assigned to Senate Commerce & Labor General Subcommittee (2026)**Category:** Prescriber protection / transparency

[View on USLege →](https://app.uslege.ai/bills/3843314)

HB 2331State contracting restrictions on disciplined PBMsRestrictive

Bars TennCare, state insurance committees, and other state entities from contracting with any PBM disciplined by the Department of Finance and Administration or Commerce and Insurance, effective for contracts entered on or after July 1, 2026.

**Sponsor:** Ed Butler (Republican–41)**Status:** In committee: taken off notice, Insurance Subcommittee (2026)**Category:** State contract restriction

[View on USLege →](https://app.uslege.ai/bills/3842444)

SB 1796Annual public reporting of PBM violationsRestrictive

Requires the Commissioner of Commerce and Insurance to publish an annual report of PBM violations under § 56-7-3124, including investigation findings and penalties, submitted to legislative leadership and posted publicly by October 1, 2026.

**Sponsor:** Shane Reeves (Republican–14)**Status:** In committee: assigned to Senate Commerce & Labor General Subcommittee (2026)**Category:** Transparency / enforcement reporting

[View on USLege →](https://app.uslege.ai/bills/3815703)

SB 1790Non-opioid pain medication formulary parityMixed-Monitor

Requires insurers' preferred drug lists to place FDA-approved non-opioid pain medications no less favorably than opioids; a coverage-parity mandate on insurers/PBM formulary design rather than a core PBM business-practice restriction.

**Sponsor:** Shane Reeves (Republican–14)**Status:** Enacted: effective January 1, 2027**Category:** Formulary mandate (insurer-facing)

[View on USLege →](https://app.uslege.ai/bills/3815444)

### Who testified: stakeholders on the record · 6 on the record

### Testified FOR PBMs (against new regulation) · for

Michael Power

Pharmaceutical Care Management Association (PCMA)

HB 1959 / SB 2040 (FAIR Rx Act)

Presented PCMA-commissioned data projecting ~8,000 lost PBM/pharmacy jobs, 168 pharmacy closures, disrupted TRICARE mail-order benefits for 45,000 veterans, and $468M in lost savings if PBMs are barred from owning pharmacies.

Dr. Johnny Garcia

Specialty pharmacist (20 years), presenting with PCMA

HB 1959 (FAIR Rx Act)

Described specialty/mail-order pharmacy services (benefits verification, clinical assessment, financial assistance) that would be lost if PBM-affiliated pharmacies were forced to close, calling the bill "an attack on my profession."

### Testified AGAINST PBMs (for reform) · against

Bobby Wommel

Pharmacist, Park Pharmacy (independent, non-chain specialty pharmacy)

SB 2040 (FAIR Rx Act)

Testified that PBM opaqueness delayed a patient's complex medication regimen and urged passage of the Fair Rx Act to ensure transparent, fair pharmacy practices statewide.

Dr. Johnetta Blakely

Medical oncologist, Tennessee Oncology (Cookeville)

SB 2040 (FAIR Rx Act)

Said the current PBM system harms rural cancer patients through delayed/denied medications and preferred PBM-owned pharmacies, and supported banning PBM ownership of pharmacies to remove the conflict of interest.

Dr. James Griffith

Owner, three independent community pharmacies in East Tennessee

HB 1959 (FAIR Rx Act)

Argued three PBMs control ~80% of claims and reimburse their own affiliated specialty pharmacies 20-40x NADAC while steering business from independents, and rebutted opposition ad claims that the bill would close independents rather than PBM-owned pharmacies.

Zach Hanson

Rx Preferred (Tennessee-based "transparent" PBM, Mt. Juliet)

HB 1959 (FAIR Rx Act)

Testified in support as a competing PBM that has removed conflicts of interest from its own model, saying clients switching to a transparent PBM save 20-50% on drug costs, and backed the bill on behalf of independent/community pharmacies.

### Hearing clips

[

![Hearing clip: TN (HB 1959: Dr. James Griffith (against)) FAIR Rx Act, PBM oligopoly testimony](https://app.uslege.ai/api/clip-thumbnail/64efe9fd-92e2-43ac-97a7-25858c34dfa0)▶

TN (HB 1959: Dr. James Griffith (against)) FAIR Rx Act, PBM oligopoly testimony

Dr. James Griffith, independent pharmacist · 3520-3605

“The passage of this legislation is necessary because of the oligopoly that we have in pharmacy today. Three pharmacy benefit managers or PBMs control about 80% of prescription claims.”

Watch clip

](https://app.uslege.ai/share/64efe9fd-92e2-43ac-97a7-25858c34dfa0?from=clips)

Only one clippable on-topic hearing found for this state; a second real clip was not available (no other on-topic hearing or opposition testimony).

#37 of 48

#37

## Kansas

Most Restrictive

Kansas enacted a hard-hitting comprehensive PBM reform law this session (SB 20, signed Apr 9, 2026): a NADAC/WAC-plus-dispensing-fee reimbursement floor, mandatory rebate/spread reporting, pharmacy-audit standards, and unlicensed-PBM fines raised to $100,000 while prior penalty caps were deleted. A near-duplicate consumer-protection bill (SB 360) died in a House committee only because SB 20 already carried the reform. Further-reaching bills also advanced this session but died: a Prescription Drug Affordability Board with upper-payment-limit authority (SB 212), a copay-accumulator/PBM cost-sharing ban (SB 423), a Kansas PSAO licensure act (HB 2551), and an insulin-cost-cap bill barring PBM reimbursement overrides (HB 2684).

Freedom from Comprehensive Reform2/25

Few PBM Mandates3/20

Light Enforcement / No Fiduciary Duty4/20

Business-Model Freedom3/20

Limited Regulatory Reach4/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

Dinah Sykes

Democratic · Dist. 21

SB 212

Sponsored the drug-affordability board/UPL bill (SB 212) and the PBM copay-accumulator ban (SB 423).

**Why it matters:** Kansas has moved from light-touch to one of the more heavily-regulated reimbursement regimes in the region; the stalled drug-affordability-board and PSAO bills are likely to return next session with real momentum.

### Bills

SB 20Kansas consumer prescription protection and accountability actRestrictive

Enacts pharmacy-audit procedures, auditing-entity registration, PBM reporting/examination authority, and reimbursement standards barring reimbursement below NADAC (or WAC when NADAC is unavailable) plus a $10.50 dispensing fee; requires rebate pass-through, deletes prior $10,000/$50,000 penalty caps, and raises the unlicensed-PBM fine to up to $100,000.

**Sponsor:** Senate Committee on Financial Institutions and Insurance**Status:** Enacted: Approved by Governor April 9, 2026**Category:** Comprehensive PBM licensure & reimbursement reform

[View on USLege →](https://app.uslege.ai/bills/2149691)

SB 360Kansas consumer prescription protection and accountability act (companion)Restrictive

Near-duplicate of SB 20: adds pharmacy-audit standards, PBM examination/reporting rules, NADAC-based reimbursement floor with dispensing fee, and raises unlicensed-PBM fines to $100,000 while repealing several prior PBM/pharmacy-audit statutes.

**Sponsor:** Senate Committee on Financial Institutions and Insurance**Status:** Died in House Committee**Category:** PBM licensure & registration (duplicate)

[View on USLege →](https://app.uslege.ai/bills/3819027)

SB 212Prescription drug cost and affordability review actRestrictive

Creates a 5-member Prescription Drug Affordability Board and 21-member stakeholder council empowered to set upper payment limits on high-cost drugs; purchasers/payors may not pay above the limit, pharmacies may not be reimbursed below it, and the AG may seek civil enforcement.

**Sponsor:** Dinah Sykes (Democratic–21)**Status:** Died in Committee**Category:** Prescription Drug Affordability Board / upper payment limits

[View on USLege →](https://app.uslege.ai/bills/2152453)

SB 423Cost-sharing assistance counted toward deductible/out-of-pocket limitRestrictive

Requires insurers, PBMs, and PSAOs to count third-party prescription cost-sharing assistance toward a patient's deductible and annual out-of-pocket maximum when no generic/biosimilar equivalent exists, limiting a common PBM copay-accumulator practice.

**Sponsor:** Dinah Sykes (Democratic–21)**Status:** Died in Committee**Category:** Copay-accumulator ban

[View on USLege →](https://app.uslege.ai/bills/3831788)

HB 2551Kansas pharmacy services administrative organization actRestrictive

Establishes department licensure for PSAOs that negotiate with PBMs on behalf of independent pharmacies, requiring ownership disclosure, contract-copy delivery, remittance-timing rules, and barring PBM/PSAO drug-price discrimination against independent pharmacies; violations are unfair trade practices with $500/day penalties.

**Sponsor:** House Committee on Insurance**Status:** Died in Committee**Category:** PSAO licensure

[View on USLege →](https://app.uslege.ai/bills/3823579)

HB 2684Insulin price limits and affordability programRestrictive

Caps 30-day out-of-pocket insulin costs at $35 and diabetes-device costs at $100, and bars PBM/third-party reimbursement arrangements from overriding the cap or cutting pharmacy reimbursement because of it.

**Sponsor:** House Committee on Insurance**Status:** Died in Committee**Category:** Insulin cost cap / PBM override ban

[View on USLege →](https://app.uslege.ai/bills/3835462)

### Hearing clips

[

![Hearing clip: KS (SB 360: Sarah Fertig, BCBS Kansas (for)) opposes PBM reform mandate](https://app.uslege.ai/api/clip-thumbnail/0c86dd8e-0852-4dfc-a21e-adb27c7186fb)▶

KS (SB 360: Sarah Fertig, BCBS Kansas (for)) opposes PBM reform mandate

Sarah Fertig, Blue Cross Blue Shield of Kansas: opponent testimony, House Committee on Insurance · 3815-3936

“We oppose this bill on behalf of our members because the bill protects big business at the expense of the little guy.”

Watch clip

](https://app.uslege.ai/share/0c86dd8e-0852-4dfc-a21e-adb27c7186fb?from=clips)

Only one clippable on-topic hearing found for this state; a second real clip was not available (no other on-topic hearing or opposition testimony).

## The rest of the country

#1 of 48

#1

## Wyoming

Friendly

Wyoming introduced no PBM-specific bill (no licensure, transparency, spread-pricing ban, fiduciary duty, reimbursement floor or anti-steering measure) in either its 2025 or 2026 session. The only pricing-adjacent measures were Hospital Price Transparency Act bills (HB 121/2025 failed 14-16 on third reading; HB 179/2026 failed introduction; SF 57/2026 enacted but targets hospital, not PBM, pricing disclosure) and SF 121/2026 (enacted Wyoming Pharmacy Act amendments expanding pharmacist collaborative-care scope of practice, unrelated to PBM regulation).

Freedom from Comprehensive Reform20/25

Few PBM Mandates16/20

Light Enforcement / No Fiduciary Duty16/20

Business-Model Freedom12/20

Limited Regulatory Reach8/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

No sponsor-derived skeptics.

**Why it matters:** Wyoming is essentially unregulated on PBMs this cycle: no PBM licensure, transparency, spread-pricing, or reimbursement-floor mandate has even been introduced across two sessions -- the enacted hospital price-transparency framework (SF 57) is worth monitoring only in case it is later expanded to reach PBM contracts.

### Bills

No current-session bills on this topic.

### Hearing clips

No clip available. Wyoming introduced no PBM-specific bill across 2025 or 2026, and no on-topic PBM-regulation hearing exists. The single PBM reference on record (House Labor, Health & Social Services, 2 March 2026) is an incidental billing-fee answer during an SF 121 pharmacist-scope-of-practice hearing rather than PBM-policy testimony, too far off-topic to represent the state.

#2 of 48

#2

## South Dakota

Friendly

South Dakota has no dedicated PBM-reform bill (no licensure overhaul, spread-pricing ban, fiduciary duty, or reimbursement floor) in the 2025 or 2026 sessions. The only PBM-adjacent, enacted measure is HB 1292 (2026, signed), which caps how long health carriers (including PBMs administering pharmacy claims) can retroactively recoup paid claims. General pharmacy-licensure modernization (SB 14, 2026; HB 1016, 2025) and a 340B manufacturer-interference bar (SB 154, 2025) touch drug distribution but do not regulate the PBM business model itself.

Freedom from Comprehensive Reform21/25

Few PBM Mandates13/20

Light Enforcement / No Fiduciary Duty13/20

Business-Model Freedom13/20

Limited Regulatory Reach10/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

Sydney Davis

Republican · Dist. 17

HB 1292

Sponsored the enacted claim-recoupment time limit that restricts PBM/health-carrier clawback practices.

**Why it matters:** SD remains a light-touch, largely status-quo state: no comprehensive reform is active, though the enacted claim-recoupment limit (HB 1292) is a modest compliance item affecting claims-processing timelines.

### Bills

HB 1292Limit the ability of a health carrier to recoup, recover, or retroactively deny previously paid claimsRestrictive

Restricts health carriers (including PBMs processing pharmacy claims) to an 18-month window for recouping or retroactively denying previously paid claims, with limited exceptions, and bars tacking on fees, penalties, or interest to any repayment demand.

**Sponsor:** Sydney Davis (Republican–17)**Status:** Enacted: Signed by the Governor, 2026**Category:** Claim recoupment limits

[View on USLege →](https://app.uslege.ai/bills/3835250)

SB 14Modify provisions related to the practice of pharmacyMixed-Monitor

Updates pharmacy-practice terminology and licensing/ownership-change procedures, authorizes remote drug drop sites, and clarifies license suspension/revocation grounds: a modernization bill that does not touch PBM contracting, reimbursement, or transparency.

**Sponsor:** Senate Health and Human Services Committee**Status:** Enacted: Signed by the Governor, 2026**Category:** Pharmacy licensure modernization

[View on USLege →](https://app.uslege.ai/bills/3788186)

HB 1016Revise provisions related to pharmacy and to increase feesMixed-Monitor

Consolidates and updates pharmacy licensing statutes, raises various pharmacy fees, and mandates new telepharmacy rules; a housekeeping/licensing bill, not a PBM-regulation measure.

**Sponsor:** House Health and Human Services Committee**Status:** Enacted: Signed by the Governor, 2025**Category:** Pharmacy licensure & fees

[View on USLege →](https://app.uslege.ai/bills/3251408)

SB 154Prohibit pharmaceutical manufacturers from interfering in contracts between 340B entities and pharmaciesMixed-Monitor

Bars pharmaceutical manufacturers (not PBMs) from denying or restricting 340B drug acquisition/delivery to contract pharmacies and voids improper data-submission demands; protects 340B pharmacy access but does not regulate PBM conduct.

**Sponsor:** Tim Reed (Republican)**Status:** Enacted: Signed by the Governor, 2025**Category:** 340B manufacturer restriction

[View on USLege →](https://app.uslege.ai/bills/3348908)

### Who testified: stakeholders on the record · 4 on the record

### Testified FOR PBMs (against new regulation) · for

No witnesses testified in support on the record.

### Testified AGAINST PBMs (for reform) · against

Christine Papana

VP of Value-Based Care & Employee Health Plan Administration, Monument Health (Rapid City)

HB 1292 (Limit health-carrier claim recoupment)

Testified that payer contracts let insurers/PBMs claw back claims paid years earlier with no advance notice while providers face 60-180 day appeal deadlines, and backed the bill's 18-month recoupment limit and notice requirement as a fairness guardrail.

Ali Dawes

Sanford Health

HB 1292 (Limit health-carrier claim recoupment)

Brief proponent testimony associating with Monument Health's position in support of the recoupment time limit.

Kim Malsam-Rysen

Avera

HB 1292 (Limit health-carrier claim recoupment)

Proponent testimony supporting the bill's limits on retroactive claim recoupment by health carriers/PBMs.

Tim Rave

South Dakota Association of Healthcare Organizations (SDAHO)

HB 1292 (Limit health-carrier claim recoupment)

Rose in support of the bill, associating with prior proponent testimony on limiting insurer/PBM recoupment lookback periods; no opponent testimony was offered on this bill.

### Hearing clips

No clip available. The only PBM-adjacent South Dakota hearing is Senate Health & Human Services, 2 March 2026, where Rep. Sydney Davis testified for HB 1292 (claim-recoupment time limit): and South Dakota's legislative media is copyrighted or restricted by state law, so no clip can be created from it. No other on-topic PBM footage exists in the state's 2025–26 health and insurance hearings, and South Dakota introduced no dedicated PBM-reform bill in this window.

#3 of 48

#3

## New Hampshire

Friendly

New Hampshire enacted a real, if partial, PBM oversight expansion this session: HB1268 (Enrolled, in recess pending the Governor as of 07/01/2026) tightens PBM-carrier written agreements, reporting/examination authority, raises fines to $5,000, extends MAC-pricing duties to carriers, adds on-site audit notice, pauses recoupment during timely appeals, and mandates rebate/spread-pricing disclosure: while explicitly leaving spread pricing itself permitted. A tougher companion, SB665 (fiduciary/audit duties, $10,000 fines, anti-steering), was killed on a floor vote (Inexpedient to Legislate, 5/14/2026). The state's two truly comprehensive vehicles: SB547 (outright spread-pricing ban) and SB478 (fee-only PBM compensation, statutory duty of care, private right of action): were both shelved to Interim Study rather than enacted. A narrower managed-care mandate, SB544 (formulary-notice/MAC recordkeeping), and a minor pharmacy price-disclosure bill, HB1584, are both Enrolled.

Freedom from Comprehensive Reform15/25

Few PBM Mandates10/20

Light Enforcement / No Fiduciary Duty11/20

Business-Model Freedom16/20

Limited Regulatory Reach14/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

Kristin Noble

Republican

HB 1268

Sponsored the near-enacted PBM reporting/MAC-duty/audit framework.

Donovan Fenton

Democratic

SB 544

Sponsored the enacted formulary-notice and MAC-recordkeeping mandate.

Denise Ricciardi

Republican

SB 665

Sponsored a fiduciary/audit and anti-steering PBM bill (killed on the floor, but sought tighter regulation).

Cindy Rosenwald

Democratic

SB 547

Sponsored the outright spread-pricing ban and anti-steering bill (stalled to Interim Study).

Tim McGough

Republican

SB 478

Sponsored the most comprehensive PBM reform bill: fee-only compensation, duty of care, private right of action (stalled to Interim Study).

Kelley Potenza

Republican

HB 1584

Sponsored the enacted-track pharmacy price-disclosure mandate.

**Why it matters:** NH is moving toward real disclosure, audit, and MAC-duty obligations for PBMs but has so far avoided the harder reform categories (spread-pricing bans and fiduciary duty) that stalled in Interim Study and could return next session.

### Bills

HB 1268Relative to pharmacy benefits managers, managed care laws, notice of drug pricing options and pharmacy benefit manager business practicesRestrictive

Expands the PBM definition, requires written PBM-carrier agreements, revises reporting and examination authority, raises fine caps to $5,000, extends MAC-pricing duties to health carriers with on-site-audit notice, pauses recoupment during timely appeals, and requires group-coverage disclosures on rebates and spread pricing while leaving spread pricing itself permitted.

**Sponsor:** Kristin Noble (Republican)**Status:** Enrolled (in recess of) 06/04/2026: pending Governor**Category:** PBM reporting, MAC duties & audits

[View on USLege →](https://app.uslege.ai/bills/3283635)

SB 544Relative to managed care lawsRestrictive

Lengthens formulary-deletion advance notice from 45 to 60 days, raises required notice font size, treats denial of an exception request as an adverse determination, and requires plans to keep and provide additional MAC/formulary-change records to the commissioner.

**Sponsor:** Donovan Fenton (Democratic)**Status:** Enrolled (in recess of) 06/17/2026**Category:** Formulary notice / MAC recordkeeping

[View on USLege →](https://app.uslege.ai/bills/3263992)

SB 665Relative to pharmacy benefits managers, managed care laws, notice of drug pricing options and pharmacy benefit manager business practicesRestrictive

Would have required PBM-carrier fiduciary agreements with semiannual audits, raised PBM fines to $10,000 per violation (each day separate), expanded the PBM definition, lengthened formulary notice, and barred affiliate-pharmacy steering incentives.

**Sponsor:** Denise Ricciardi (Republican)**Status:** Killed: Inexpedient to Legislate, voice vote, 05/14/2026**Category:** PBM fiduciary/audit duties

[View on USLege →](https://app.uslege.ai/bills/3835751)

SB 547Relative to regulation and transparency of pharmacy benefit manager practicesRestrictive

Would ban PBMs from retaining any spread pricing, bar incentives steering patients to PBM-affiliated pharmacies, impose written conflict-of-interest duties to carrier clients, and require quarterly transparency filings on rebates, fees, and drug spending.

**Sponsor:** Cindy Rosenwald (Democratic)**Status:** Referred to Interim Study, voice vote, 03/12/2026 (stalled)**Category:** Spread-pricing ban & transparency

[View on USLege →](https://app.uslege.ai/bills/3264012)

SB 478Relative to strengthening prescription drug affordability and pharmacy benefits manager accountabilityRestrictive

Would ban spread pricing outright, limit PBM income to disclosed bona-fide fees unrelated to drug prices or rebates, bar gag clauses and forced mail-order, protect 340B reimbursement, require insulin cost-sharing caps, and impose a statutory PBM duty of care and good faith enforceable by private civil action.

**Sponsor:** Tim McGough (Republican)**Status:** Pending Motion Interim Study, 03/12/2026 (stalled)**Category:** Comprehensive PBM reform

[View on USLege →](https://app.uslege.ai/bills/3263849)

HB 1584Relative to notice of drug pricing optionsRestrictive

Requires every licensed pharmacy to make reasonable efforts to inform consumers they can request the lowest available prescription-drug price and to disclose pricing options including cash price, coupons, discounts, and rebate programs on request.

**Sponsor:** Kelley Potenza (Republican)**Status:** Enrolled, voice vote, 07/06/2026**Category:** Pharmacy price-disclosure notice

[View on USLege →](https://app.uslege.ai/bills/3499649)

### Who testified: stakeholders on the record · 5 on the record

### Testified FOR PBMs (against new regulation) · for

Margaret Reynolds

Government Affairs Senior Director, Cigna (representing Express Scripts)

SB 547

Opposed the bill's fiduciary-duty mandate (called PBMs 'fundamentally not a fiduciary'), the spread-pricing ban, and the broad PBM/affiliate definitions that could sweep in workers' comp and other non-health lines.

Cam Lapine

Lobbyist for Cigna / American Property Casualty Insurance Association / NH Association of Domestic Insurance Companies

SB 547

Argued the bill's PBM/affiliate definitions were overbroad and would improperly sweep workers'-compensation and property-casualty carriers into PBM regulation where consumers pay nothing out of pocket.

Peter Bragdon

Harvard Pilgrim Health Care

SB 547

Opposed the spread-pricing ban specifically, arguing it would transfer pricing risk back to insurers and raise premiums, disadvantaging a regional non-profit insurer relative to larger carriers that own their own PBMs.

Sam Hollemeier

Pharmaceutical Care Management Association (PCMA)

SB 547

Testified in opposition on behalf of PCMA, projecting a $100M/year ($1B over 10 years) cost to New Hampshire from the fiduciary duty, spread-pricing ban, preferred-network restrictions, and new reporting mandates; called it a solution in search of a problem.

Curtis Barry

Pharmaceutical Care Management Association (PCMA)

SB 547

Supported Hollemeier's opposition testimony, arguing the bill's competition rationale was flawed (comparing PBM market concentration to fast-food chains) and that it improperly lets government dictate contract terms between sophisticated private parties.

### Testified AGAINST PBMs (for reform) · against

No witnesses testified in opposition on the record.

### Hearing clips

[

![Hearing clip: NH: SB 547: Senate HHS committee member (against)](https://app.uslege.ai/api/clip-thumbnail/c622f032-d2e0-4bb7-895e-29b4c6299721)▶

NH: SB 547: Senate HHS committee member (against)

Unidentified NH Senate Health & Human Services committee member (transcript renders name inconsistently as 'Bertzel'/'Bertsell'/'Birdsell') · 1107-1201

“I think the language in there is an excellent starting place for improving regulation and transparency in pharmacy benefit manager practices in the state of New Hampshire. One of the points that Senator Rosenwald brought up is classification of PBMs as a fiduciary... the major points brought up in this piece of legislation will be addressed in other pieces.”

Watch clip

](https://app.uslege.ai/share/c622f032-d2e0-4bb7-895e-29b4c6299721?from=clips)[

![Hearing clip: NH: SB 665: Curtis, insurer/PBM contracting witness (for)](https://app.uslege.ai/api/clip-thumbnail/9fdf0c98-2372-4ddc-a64a-876bf4d938e8)▶

NH: SB 665: Curtis, insurer/PBM contracting witness (for)

"Curtis" (witness explaining PBM/insurer contracting practices; full name/affiliation not stated in transcript) · 4912-5030

“The premise that the PBMs or a carrier tells the pharmacy 'you can't discuss this with the patient': that is absolutely not true... there are two provisions on the statutes currently that address this area... the PBM of the carrier cannot, according to the statute, tell the pharmacy you can't discuss that with the patient.”

Watch clip

](https://app.uslege.ai/share/9fdf0c98-2372-4ddc-a64a-876bf4d938e8?from=clips)

#4 of 48

#4

## Mississippi

Mixed

Mississippi has tried, and failed, to enact comprehensive PBM reform in back-to-back sessions: nearly identical Pharmacy Benefit Prompt Pay Act overhauls (SB 2576, HB 1674, HB 1666, HB 1672, SB 2575) plus an anti-steering bill (HB 558) all Died In Committee on 2026-02-03. The 2025 predecessor got furthest (HB 1123 passed the full House before dying in conference) showing real but ultimately unsuccessful momentum. No comprehensive PBM licensure/fiduciary-duty regime is enacted.

Freedom from Comprehensive Reform9/25

Few PBM Mandates11/20

Light Enforcement / No Fiduciary Duty9/20

Business-Model Freedom13/20

Limited Regulatory Reach8/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

Jason White

R · Dist. House (Speaker)

HB 1123 (2025)

Sponsor of the comprehensive PBM/PSAO transparency bill that passed the full House before dying in conference: the closest MS has come to enacting comprehensive PBM reform.

Jeremy England

R · Dist. Senate 51

SB 2576

Sponsor of the 2026 comprehensive Prompt Pay Act overhaul (spread-pricing ban, PSAO regulation, independent-pharmacy grants).

Henry Zuber III

R · Dist. House 113

HB 1666

Sponsor of the 2026 comprehensive PBM/PSAO transparency and reimbursement bill.

Gene Newman

R · Dist. House

HB 558

Sponsor of the anti-steering bill barring PBM-owned-pharmacy mandates.

**Why it matters:** Mississippi is a genuine swing state: reform has repeatedly cleared subcommittee/floor stages (one bill passed the full House in 2025) only to die before final passage. The same GOP-authored package will likely be refiled again, with the State Affairs and Public Health and Welfare committees the key stage where it has stalled.

### Bills

SB 2576Pharmacy benefit managers; revise provisions related toRestrictive

Expands the Pharmacy Benefit Prompt Pay Act: transparency mandates, spread-pricing ban, PSAO reporting, licensing/appeal procedures, non-retaliation protections, and a grant program for independent pharmacies.

**Sponsor:** Jeremy England (R–Senate 51)**Status:** Died In Committee (2026-02-03)**Category:** Comprehensive PBM/PSAO reform

[View on USLege →](https://app.uslege.ai/bills/3817260)

HB 1666Pharmacy Benefit Prompt Act; reviseRestrictive

Regulates PBMs and PSAOs with transparency requirements, spread-pricing ban, timely-claims-payment and reimbursement standards, licensing/audit provisions, and a grant program for independent community pharmacies.

**Sponsor:** Henry Zuber III (R–House 113)**Status:** Died In Committee (2026-02-03)**Category:** Comprehensive PBM/PSAO reform

[View on USLege →](https://app.uslege.ai/bills/3818351)

SB 2575Pharmacy Benefit Prompt Pay Act; revise and create additional provisionsRestrictive

Creates the Mississippi Specialty Drug Committee, a Pharmacy Fair Competition Act barring PBM/pharmacy conflicts of interest, and licensing/reporting mandates for PBMs and PSAOs enforced by the Board of Pharmacy.

**Sponsor:** Rita Parks (R–Senate (district not confirmed))**Status:** Died In Committee (2026-02-03)**Category:** Comprehensive PBM/PSAO reform

[View on USLege →](https://app.uslege.ai/bills/3817259)

HB 558Pharmacy services; prohibit insurers and PBMs from requiring exclusive use of owned pharmaciesRestrictive

Bars insurers/PBMs from requiring patients to use PBM-owned pharmacies, from imposing higher costs for choosing other pharmacies, and from underpaying non-owned pharmacies.

**Sponsor:** Gene Newman (R–House (district not confirmed))**Status:** Died In Committee (2026-02-03)**Category:** Anti-steering

[View on USLege →](https://app.uslege.ai/bills/3800956)

HB 1123 (2025)Pharmacy benefit managers and pharmacy services administrative organizations; regulationsRestrictive

Would have banned spread pricing, mandated detailed cost reporting to the Board of Pharmacy from manufacturers/PBMs/PSAOs/insurers, and set audit/penalty and anti-retaliation protections: the furthest any MS PBM reform bill has advanced, dying only in conference.

**Sponsor:** Jason White (R–House (Speaker))**Status:** Passed House 2025-01-23; amended by Senate; Died In Conference (2025-04-03)**Category:** Comprehensive PBM/PSAO reform

[View on USLege →](https://app.uslege.ai/bills/2189239)

HB 1119 (2025)Pharmacy benefit managers; revise provisions related toRestrictive

Would have mandated NADAC-plus-dispensing-fee reimbursement, prompt payment, an appeal process, and barred PBMs from steering patients or penalizing pharmacies for exercising rights under the act.

**Sponsor:** Stacey Hobgood-Wilkes (R–House (district not confirmed))**Status:** Died In Committee (2025-02-04)**Category:** Reimbursement floor / anti-steering

[View on USLege →](https://app.uslege.ai/bills/2189240)

### Hearing clips

[

![Hearing clip: MS (HB 1665: House floor sponsor (against)) "This is the PBM reform bill"](https://app.uslege.ai/api/clip-thumbnail/4ae97bcd-7ca1-4426-a089-30396490a5a7)▶

MS (HB 1665: House floor sponsor (against)) "This is the PBM reform bill"

House bill sponsor (Jackson County-area delegation; not independently confirmed by name from the floor transcript) · 18980-19113

“This bill completely stops spread pricing. It also requires all rebates to go back to the plan employer or the sponsor.”

Watch clip

](https://app.uslege.ai/share/4ae97bcd-7ca1-4426-a089-30396490a5a7?from=clips)

Only one clippable on-topic hearing found for this state; a second real clip was not available (no other on-topic hearing or opposition testimony).

#5 of 48

#5

## South Carolina

Mixed

South Carolina has an existing baseline PBM statute (Title 38, Ch. 71, Art. 22) that this session's bills seek to expand rather than replace: HB 4794 (PBM Trade Practices -- spread-pricing ban, anti-steering disclosure), HB 4790 (MAC-list access/appeals), HB 4791 (NADAC-plus-dispensing-fee reimbursement floor), and HB 4792 (raises PBM penalties/fees) are all still in committee as of mid-2026 with no floor vote in either chamber. A companion copay-accumulator bill (SB 100/HB 3575) has been stalled in committee since early 2025.

Freedom from Comprehensive Reform12/25

Few PBM Mandates10/20

Light Enforcement / No Fiduciary Duty10/20

Business-Model Freedom10/20

Limited Regulatory Reach8/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

Heath Sessions

R · Dist. 46

HB 4794 / HB 4790 / HB 4791 / HB 4792

Lead sponsor of South Carolina's coordinated seven-bill PBM-reform package covering spread pricing, MAC transparency, reimbursement floors, and penalties.

Michael Gambrell

R · Dist. 4

SB 100

Sponsor of the Senate copay-accumulator-ban bill requiring PBMs to count manufacturer assistance toward cost-sharing.

**Why it matters:** South Carolina is moderately exposed to reform but has not yet acted: a coordinated seven-bill PBM-reform package (HB 4790-4796) is pending with Republican sponsorship, meaning the current business-friendly status quo could shift quickly if any of the package advances.

### Bills

HB 4794Pharmacy Benefits Managers -- Trade PracticesRestrictive

Defines spread pricing and specialized delivery drugs, bans undisclosed patient steering, mandates rebate-sharing transparency at point of sale, and sets timely-claims and tax-remittance standards for PBMs.

**Sponsor:** Heath Sessions (R–46)**Status:** Pending, Committee (sponsors added through Feb. 2026)**Category:** Spread pricing / anti-steering

[View on USLege →](https://app.uslege.ai/bills/3801768)

HB 4790PBM Maximum Allowable Cost ListsRestrictive

Requires PBMs to give network pharmacies unobstructed, weekly-updated access to MAC lists, bars dispensing fees from MAC calculations, and creates internal/external appeal rights for reimbursement disputes.

**Sponsor:** Heath Sessions (R–46)**Status:** Pending, Committee (sponsors added through April 2026)**Category:** MAC transparency

[View on USLege →](https://app.uslege.ai/bills/3801764)

HB 4791Drug acquisition cost surveys and reimbursement floorRestrictive

Mandates pharmacy cooperation with NADAC surveys and sets a reimbursement floor of NADAC (or WAC) plus a Medicaid-level dispensing fee, enforced by the Department of Insurance with penalties.

**Sponsor:** Heath Sessions (R–46)**Status:** Pending, Committee (sponsors added through April 2026)**Category:** Reimbursement floor

[View on USLege →](https://app.uslege.ai/bills/3801765)

HB 4792PBM penalties and license fees increaseRestrictive

Substantially raises administrative fine limits for insurers, PBMs, and HMOs, and increases PBM licensing application and renewal fees.

**Sponsor:** Heath Sessions (R–46)**Status:** Pending, Committee (sponsors added through Feb. 2026)**Category:** Enforcement / penalties

[View on USLege →](https://app.uslege.ai/bills/3801766)

SB 100Pharmacy insurance benefits cost-sharingRestrictive

Requires PBMs and insurers to count all cost-sharing payments, including manufacturer financial assistance, toward enrollee out-of-pocket contributions.

**Sponsor:** Michael Gambrell (R–4)**Status:** Stalled (referred Jan. 2025, no further action)**Category:** Copay accumulator ban

[View on USLege →](https://app.uslege.ai/bills/2041949)

HB 4796PBM/PSAO Department of Insurance examinationsRestrictive

Subjects PBM and PSAO compliance examinations to standard Title 38 examination procedures and requires the entities to pay examination costs.

**Sponsor:** Marvin Smith (R)**Status:** Pending, Committee, Jan. 2026**Category:** Examination authority

[View on USLege →](https://app.uslege.ai/bills/3801770)

### Who testified: stakeholders on the record · 3 on the record

### Testified FOR PBMs (against new regulation) · for

Trey Walker

Executive Director, South Carolina Alliance of Health Plans

HB 4794 (PBM Trade Practices)

Opposed the bill on behalf of commercial insurers/Medicaid MCOs, defending spread pricing as a common, employer-preferred cost-predictability arrangement analogous to travel-booking markups and warning against regulatory interference in PBM-insurer contracts.

Michael Power

Pharmaceutical Care Management Association (PCMA)

HB 4794 / HB 4791

Opposed both bills, arguing the anti-steering provisions may violate free-speech precedent set in a Texas case, that federal law already requires 100% rebate pass-through so the state rebate mandate would conflict with federal law, and that a mandated reimbursement floor exceeds market rates.

### Testified AGAINST PBMs (for reform) · against

John Pugh

Pharmacist/owner, Prosperity Drug (Prosperity & Leesville, SC)

HB 4794 (PBM Trade Practices)

Said his rural pharmacies are reimbursed below acquisition cost on ~25% of prescriptions and backed the bill's reimbursement floor as necessary to keep independent pharmacies operating in underserved areas.

### Hearing clips

[

![Hearing clip: SC (S.342: Senator from Dorchester (for)) opposes government price floor on PBMs](https://app.uslege.ai/api/clip-thumbnail/eee8c883-f8b4-42b5-86c6-826f57da18ee)▶

SC (S.342: Senator from Dorchester (for)) opposes government price floor on PBMs

Senator from Dorchester (SC Senate Banking & Insurance Cmte.) · 793-845

“The problem for me, mister chairman, I'll be very candidly, is on the price setting on the government side: setting a price floor, if you will, on the PBMs.”

Watch clip

](https://app.uslege.ai/share/eee8c883-f8b4-42b5-86c6-826f57da18ee?from=clips)

Only one clippable on-topic hearing found for this state; a second real clip was not available (no other on-topic hearing or opposition testimony).

#6 of 48

#6

## Pennsylvania

Mixed

Pennsylvania's baseline is the 2016 Pharmacy Audit Integrity and Transparency Act, a narrow audit-focused PBM law. The 2025-26 session has multiple bills to expand it (SB 1186/HB 2270 add a 'State pharmacy benefits manager' provision; HB 2431 broadens enforcement authority) plus a copay-accumulator ban (HB 2652/HB 2226, credits direct-purchase costs to out-of-pocket maximums) and a mid-year formulary-change lock (HB 2648) -- all still sitting in committee/Rules as of mid-2026 with no floor votes.

Freedom from Comprehensive Reform10/25

Few PBM Mandates10/20

Light Enforcement / No Fiduciary Duty9/20

Business-Model Freedom9/20

Limited Regulatory Reach8/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

Emily Kinkead

D · Dist. 20

HB 2652 / HB 2226

Sponsor of Pennsylvania's copay-accumulator-ban bills limiting PBM cost-sharing calculations.

Lisa Boscola

D · Dist. 18

SB 1186

Sponsor of the Senate bill expanding the state's PBM audit law with a new state-PBM contract provision.

Frank Burns

D · Dist. 72

HB 2431

Sponsor of the bill broadening enforcement authority under the Pharmacy Audit Integrity and Transparency Act.

**Why it matters:** Pennsylvania bears close monitoring: none of this session's PBM bills have passed either chamber, so the existing regime stays narrow, but a large slate of pending bills (accumulator ban, PBM Act expansion, formulary lock) could move quickly if committee posture shifts.

### Bills

HB 2652Prescription drug cost credits (copay accumulator ban)Restrictive

Requires PBMs/insurers to credit direct-purchase prescription drug payments toward in-network out-of-pocket maximums, with penalties for noncompliance.

**Sponsor:** Emily Kinkead (D–20)**Status:** Re-committed to Rules, June 2026**Category:** Copay accumulator ban

[View on USLege →](https://app.uslege.ai/bills/3886087)

HB 2226Prescription drug cost credits (companion)Restrictive

Companion copay-accumulator-ban bill requiring PBM/insurer crediting of manufacturer or third-party drug payments toward cost-sharing.

**Sponsor:** Emily Kinkead (D–20)**Status:** Re-committed to Rules, June 2026**Category:** Copay accumulator ban

[View on USLege →](https://app.uslege.ai/bills/3852138)

SB 1186State pharmacy benefits manager provisionRestrictive

Amends the Pharmacy Audit Integrity and Transparency Act's definitions and adds a 'State pharmacy benefits manager' contract provision.

**Sponsor:** Lisa Boscola (D–18)**Status:** Referred to Health & Human Services, March 2026**Category:** PBM Act expansion

[View on USLege →](https://app.uslege.ai/bills/3864516)

HB 2270State pharmacy benefits manager provision (House companion)Restrictive

House companion to SB 1186 amending the Pharmacy Audit Integrity and Transparency Act to add state PBM contract provisions.

**Sponsor:** Robert Matzie (D)**Status:** Referred to Health, March 2026**Category:** PBM Act expansion

[View on USLege →](https://app.uslege.ai/bills/3866607)

HB 2431Pharmacy Audit Integrity Act enforcement expansionRestrictive

Broadens the scope of enforcement authority under the existing Pharmacy Audit Integrity and Transparency Act.

**Sponsor:** Frank Burns (D–72)**Status:** Referred to Health, April 2026**Category:** Enforcement authority

[View on USLege →](https://app.uslege.ai/bills/3875762)

HB 2648Mid-year formulary/coverage change restrictionsRestrictive

Would bar insurers and PBMs from altering drug coverage terms mid-plan-year, requiring uniform renewal-time changes with advance notice.

**Sponsor:** Tarik Khan (D)**Status:** Referred to Consumer Protection, Technology & Utilities, June 2026**Category:** Formulary lock

[View on USLege →](https://app.uslege.ai/bills/3886207)

### Who testified: stakeholders on the record · 5 on the record

### Testified FOR PBMs (against new regulation) · for

Emily Katz

Executive Director, PAMCO (Pennsylvania Association of Medicaid Managed Care Organizations)

HB 2270 (State pharmacy benefits manager provision)

Opposed mandating a single state PBM, warning of ~$100M/year added cost, major member disruption (citing Louisiana's tumultuous rollout), and arguing existing DHS contract provisions already ban spread pricing, clawbacks and steering.

### Testified AGAINST PBMs (for reform) · against

Antonio Ciaccia

CEO, 46brooklyn Research (drug-pricing research nonprofit)

HB 2270 (State pharmacy benefits manager provision)

Detailed how PBMs used overpay-then-clawback schemes and inflated specialty-drug markups (e.g. $600-$4,600 per claim) to hide spread pricing even after states banned it, arguing conflicted PBM pricing control drives up Medicaid costs.

Scott Newton

Pharmacist/owner, Ganz Drug Store (Warren, PA)

HB 2270 (State pharmacy benefits manager provision)

Testified that PBM reimbursement below acquisition cost forced 10% of his claims to lose money, driving 70-to-50-hour cuts and closures; supported moving Medicaid to a single PBM with NADAC-based pricing.

Rick Seipe

President, Value Drug Company / Value Specialty Pharmacy

HB 2270 (State pharmacy benefits manager provision)

Said MCO-contracted PBMs now pay only 50-80% of the 2017 fee-for-service dispensing fee and backed consolidating Medicaid pharmacy administration under one PBM with NADAC-plus-dispensing-fee reimbursement.

Ron McDermott

VP, Hometown Pharmacies (owns pharmacies in both PA and OH)

HB 2270 (State pharmacy benefits manager provision)

Contrasted Ohio's single-PBM model (higher dispensing fees, $333M administrative savings, pharmacies reopening) with Pennsylvania's continuing closures, and urged PA to adopt the same PBM oversight model.

### Hearing clips

[

![Hearing clip: PA (HB 305: Michelle Kremens (Prime Therapeutics) (for)) PBM defends spread pricing](https://app.uslege.ai/api/clip-thumbnail/11d72534-0bc4-4731-9ea5-663096aed836)▶

PA (HB 305: Michelle Kremens (Prime Therapeutics) (for)) PBM defends spread pricing

Michelle Kremens, Prime Therapeutics (PBM) · 2805-2917

“There's a lot of times PBMs actually lose money, I can confirm that Prime Therapeutics does lose money on some claims with spread pricing.”

Watch clip

](https://app.uslege.ai/share/11d72534-0bc4-4731-9ea5-663096aed836?from=clips)[

![Hearing clip: PA (HB 305: Rep. Nelson (against)) challenges PBM on spread-pricing costs](https://app.uslege.ai/api/clip-thumbnail/9c189782-11ed-45bd-a355-47f82035bf39)▶

PA (HB 305: Rep. Nelson (against)) challenges PBM on spread-pricing costs

Rep. Nelson (PA House) · 2762-2822

“I would suggest almost as a PBM you are one of the contributing factors to excessive cost and creating considerable difficulties in the market as it lies.”

Watch clip

](https://app.uslege.ai/share/9c189782-11ed-45bd-a355-47f82035bf39?from=clips)

#7 of 48

#8

## Idaho

Restrictive

Idaho enacted HB 596 in 2024 (effective Jan 1, 2025), a substantive PBM law requiring pass-through pricing (a spread-pricing ban), rebate reporting, network-adequacy standards, limits on patient steering, restrictions on arbitrary accreditation, and reimbursement-appeal processes: placing Idaho well into reform territory rather than at the light-touch pole. SB 1367 (2026), a committee-authored measure adding NADAC+dispensing-fee reimbursement floors, was introduced March 4, 2026 and stalled in Commerce & Human Resources. (Adjacent 340B, pharmacist-licensing, and copay-accumulator bills were excluded as non-core.)

Freedom from Comprehensive Reform6/25

Few PBM Mandates5/20

Light Enforcement / No Fiduciary Duty8/20

Business-Model Freedom12/20

Limited Regulatory Reach13/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

No sponsor-derived skeptics.

**Why it matters:** Idaho already regulates PBMs meaningfully through HB 596 (pass-through pricing, anti-steering, network adequacy, reimbursement appeals), placing it in the moderate-reform range rather than the light-touch pole; SB 1367 would add reimbursement floors on top.

### Bills

SB 1367Pharmacy benefit managersRestrictive

Establishes strict PBM regulatory requirements including minimum reimbursement rates for independent pharmacies (NADAC plus a minimum dispensing fee with annual inflation adjustment), transparency, anti-competitive-practice prohibitions, and detailed reporting/contract provisions.

**Sponsor:** Senate State Affairs Committee**Status:** Introduced; referred to Commerce & Human Resources (March 2026); no further action recorded: stalled**Category:** Reimbursement floor & transparency

[View on USLege →](https://app.uslege.ai/bills/3860274)

### Hearing clips

[

![Hearing clip: ID (SB 1367: Sen. Camille Blaylock (against)) introduces PBM dispensing-fee & reimbursement bill](https://app.uslege.ai/api/clip-thumbnail/7436e1aa-932c-467a-854a-c550b81469fa)▶

ID (SB 1367: Sen. Camille Blaylock (against)) introduces PBM dispensing-fee & reimbursement bill

Sen. Camille Blaylock, District 11 · 06:30-07:55

“RS33536 deals with pharmacy benefit managers, also known as PBMs. This legislation will do two things: first, it establishes a clear dispensing fee and reimbursement rates for independent pharmacies in our state.”

Watch clip

](https://app.uslege.ai/share/7436e1aa-932c-467a-854a-c550b81469fa?from=clips)

Only one clippable on-topic hearing found for this state; a second real clip was not available (no other on-topic hearing or opposition testimony).

#8 of 48

#7

## Missouri

Restrictive

Missouri has no enacted comprehensive PBM law, but bipartisan (mostly GOP) reform has advanced further here than in most states: HB 840 and HB 982 both cleared House committee with 'Do Pass' votes in 2025, and SB 984/968 (combined via Senate Committee Substitute) passed committee 2026-03-25 and reached the Senate floor on 2026-04-20 with two amendments adopted, then stalled on the Informal Calendar rather than receiving final passage.

Freedom from Comprehensive Reform10/25

Few PBM Mandates10/20

Light Enforcement / No Fiduciary Duty8/20

Business-Model Freedom10/20

Limited Regulatory Reach6/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

Jill Carter

R · Dist. Senate 32

SB 984

Sponsor of the comprehensive PBM audit/pricing/rebate overhaul that reached a live Senate floor debate with amendments in April 2026.

Bennie Cook

R · Dist. House

HB 840

Sponsor of a PBM reform bill that cleared House committee 11-0-2 in 2025.

John Hewkin

R · Dist. House

HB 982

Sponsor of a PBM fiduciary-duty/MAC-appeal bill reported Do Pass by House committee in 2025.

Gregg Bush

D · Dist. House

HB 2645

Democratic sponsor of a 2026 PBM overcharge-prevention and transparency bill, showing bipartisan reform interest.

**Why it matters:** Missouri is a high-priority active-session state: SB 984 got to a live Senate floor debate with amendments in April 2026 and was only shelved procedurally (Informal Calendar), not defeated; it or a similar vehicle is likely to resurface and could reach final passage next session.

### Bills

SB 984Modifies provisions relating to pharmacy benefit managersRestrictive

Repeals and replaces Missouri's PBM statute with new audit-procedure limits, pricing-transparency and rebate-reporting mandates, pharmacy-contract term standards, and fiduciary duties for PBMs; combined with SB 968 via Senate Committee Substitute.

**Sponsor:** Jill Carter (R–Senate 32)**Status:** SCS reported from committee (2026-03-25); Senate floor amendments adopted/defeated 2026-04-20; placed on Informal Calendar (stalled short of final passage)**Category:** Comprehensive PBM audit & pricing reform

[View on USLege →](https://app.uslege.ai/bills/3372338)

HB 840 (2025)Creates provisions relating to payments for prescription drugsRestrictive

Enhances patient freedom to choose pharmacies, regulates PBMs for transparent fair pricing and reimbursement, protects pharmacies from certain fees, and sets patient copayment limits with out-of-pocket-maximum inclusion rules.

**Sponsor:** Bennie Cook (R–House (district not confirmed))**Status:** HCS Reported Do Pass, House committee, 11-0-2 (2025-03-12)**Category:** Patient choice / reimbursement transparency

[View on USLege →](https://app.uslege.ai/bills/2153622)

HB 982 (2025)Creates provisions relating to payments for prescription drugsRestrictive

Bars PBMs from restricting where patients fill prescriptions, requires rebate-arrangement disclosure, limits patient out-of-pocket costs, and imposes fiduciary duties plus a MAC reimbursement appeals process.

**Sponsor:** John Hewkin (R–House (district not confirmed))**Status:** Reported Do Pass, House committee (2025-04-30)**Category:** Patient choice / MAC / fiduciary duty

[View on USLege →](https://app.uslege.ai/bills/2153671)

SB 512 (2025)Enacts provisions relating to payments for prescription drugsRestrictive

Guarantees free pharmacy choice, limits PBM cost-share structuring, mandates transparency in PBM pricing/rebates, requires fair pharmacy reimbursement, and imposes fiduciary duty and MAC-pricing/appeal regulation.

**Sponsor:** Mike Bernskoetter (R–Senate (district not confirmed))**Status:** Second read and referred to Families, Seniors and Health Committee (2025-02-27), stalled**Category:** Patient choice / MAC / fiduciary duty

[View on USLege →](https://app.uslege.ai/bills/2154956)

HB 2645 (2026)Modifies provisions relating to payments for prescription drugsRestrictive

Bars PBMs from overcharging patients at point of sale, protects pharmacists' right to discuss pricing/alternatives with patients, and requires PBM disclosure of conflicts of interest and cost-increasing actions; excludes Medicare Part D.

**Sponsor:** Gregg Bush (D–House (district not confirmed))**Status:** Prefiled 2026-01-02, referred to Emerging Issues committee (H), early stage**Category:** Overcharge prevention / transparency

[View on USLege →](https://app.uslege.ai/bills/3789106)

SB 45 (2025)Enacts provisions relating to payments for prescription drugsRestrictive

Prohibits PBMs from directing patients away from chosen pharmacies, requires cost disclosures, limits copayments, mandates fair MAC pricing, and imposes fiduciary duties and conflict-of-interest disclosure on PBMs.

**Sponsor:** Travis Fitzwater (R–Senate 10)**Status:** Informal Calendar S Bills for Perfection (2025-05-30), carried over/stalled**Category:** Patient choice / MAC / fiduciary duty

[View on USLege →](https://app.uslege.ai/bills/2154506)

### Who testified: stakeholders on the record · 1 on the record

### Testified FOR PBMs (against new regulation) · for

No witnesses testified in support on the record.

### Testified AGAINST PBMs (for reform) · against

Missouri Pharmacy Association representative (name garbled in transcript audio)

Missouri Pharmacy Association

HB 840 / HB 982

At the joint House Health and Mental Health Committee hearing on HB840/HB982, walked the committee through FTC's 2024-25 PBM reports, explaining how PBM rebate demands inflate list prices (and copays with them) and how PBM-owned specialty pharmacies were paid thousands-of-percent markups versus independents; urged passage of the bills' anti-clawback, fiduciary-duty, and pharmacy-choice protections.

### Hearing clips

Clip captured but thumbnail failed to render server-side after extended wait; dropped to keep the report honest.

#9 of 48

#9

## Arizona

Restrictive

Arizona has not enacted a comprehensive PBM pricing/mandate law, but reform bills are actively advancing across two sessions: HB4124 (2026, pending Second Reading) would impose reimbursement floors, transparency reporting, a spread-pricing ban, and a monitoring council; SB1710 (patient-steering ban + annual transparency reports) and SB1545 (bars PBMs from owning retail pharmacy permits) are both pending in Senate Rules. One narrower measure, SB1102 (formulary/coverage-continuity mandate), is already signed into law. A related workers'-comp PBM-network bill (HB2813) FAILED in 2026, showing reform has real but incomplete traction.

Freedom from Comprehensive Reform10/25

Few PBM Mandates8/20

Light Enforcement / No Fiduciary Duty8/20

Business-Model Freedom10/20

Limited Regulatory Reach6/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

Lorena Austin

D · Dist. 9

HB 4124

Sponsored the comprehensive 2026 reimbursement/transparency/anti-steering PBM bill.

Selina Bliss

R · Dist. 1

HB 2208

Sponsored the reimbursement-floor and appeals-process bill across two sessions.

Janae Shamp

R · Dist. 29

SB 1710

Sponsored the enacted formulary-continuity law plus pending anti-steering and PBM pharmacy-ownership ban bills.

**Why it matters:** Arizona is a swing state: no comprehensive law is locked in yet, but HB4124, SB1710, and SB1545 would each meaningfully cut into PBM margin and ownership flexibility if they clear the Legislature.

### Bills

HB 4124Health insurance; pharmacy; reimbursement ratesRestrictive

Mandates PBMs reimburse pharmacies at or above acquisition cost, requires disclosure of fees/rebates, prohibits spread pricing and conflicted patient steering, and requires annual transparency reports plus a monitoring advisory council.

**Sponsor:** Lorena Austin (D–9)**Status:** House Second Reading**Category:** Reimbursement floor / transparency / anti-steering

[View on USLege →](https://app.uslege.ai/bills/3843569)

HB 2208Pharmacists; pharmacies; reimbursement costs; appealsRestrictive

Bars PBMs from reimbursing below actual acquisition cost, mandates minimum dispensing fees, and requires an approved appeals process for reimbursement disputes.

**Sponsor:** Selina Bliss (R–1)**Status:** House Committee: Do Pass**Category:** Reimbursement / appeals

[View on USLege →](https://app.uslege.ai/bills/2030364)

HB 2196Pharmacists; pharmacies; reimbursement costs; appealsRestrictive

2026 companion requiring PBMs to reimburse nonaffiliated pharmacies at or above acquisition cost with a structured appeals process, applying to contracts renewed after Dec. 31, 2026.

**Sponsor:** Selina Bliss (R–1)**Status:** House Committee: Do Pass**Category:** Reimbursement / appeals

[View on USLege →](https://app.uslege.ai/bills/3797867)

SB 1710Pharmacy benefits; patient steering; prohibitionRestrictive

Prohibits PBMs from steering patients to affiliated pharmacies using prescription data, restricts site-of-administration cost barriers for clinician-administered drugs, and mandates annual transparency reports on rebates/fees/corporate relationships.

**Sponsor:** Janae Shamp (R–29)**Status:** Referred to Senate Rules**Category:** Anti-steering / transparency

[View on USLege →](https://app.uslege.ai/bills/3833080)

SB 1545Pharmacy benefit managers; pharmacy permitsRestrictive

Prohibits PBMs from directly or indirectly owning retail pharmacy permits, with Board of Pharmacy authority to revoke violating permits (narrow orphan-drug exception).

**Sponsor:** Janae Shamp (R–29)**Status:** Referred to Senate Rules**Category:** PBM ownership ban

[View on USLege →](https://app.uslege.ai/bills/3829955)

SB 1102Pharmacy benefits; prescribing; exemptionRestrictive

Bars PBMs from cutting off coverage for previously-approved drugs mid-plan-year and requires a transparent, timely formulary exception process.

**Sponsor:** Janae Shamp (R–29)**Status:** Signed by Governor**Category:** Formulary continuity mandate

[View on USLege →](https://app.uslege.ai/bills/2031326)

### Who testified: stakeholders on the record · 4 on the record

### Testified FOR PBMs (against new regulation) · for

Kelsey Lundy

Pharmaceutical Care Management Association (PCMA)

HB 2196

Testified in opposition to HB2196's reimbursement floor/appeal mandate, arguing it would shift ~$290M/year in costs onto employers, unions and fully-insured purchasers to benefit one industry (pharmacy) while carving out the state health plan.

Mike Huckins

Greater Phoenix Chamber

HB 2196

Opposed HB2196 on behalf of employer members, saying it restricts PBMs' ability to build competitive networks and negotiate pharmacy reimbursement, and echoed concern that the state health plan is carved out of the cost increase.

### Testified AGAINST PBMs (for reform) · against

Diane McAllister

Arizona Independent Pharmacy

HB 2196

Testified in support, describing PBM vertical integration as an inherent conflict of interest and citing FTC/state-audit findings that PBMs pay their own affiliated pharmacies far more than independents; urged a reimbursement floor tied to acquisition cost plus a fair dispensing fee.

Brianne Space

Independent pharmacy owner (Saddlebrooke, AZ)

HB 2196

Independent pharmacist testified that PBM reimbursements below acquisition cost lost her pharmacy roughly $200,000 in a year and forced her to stop filling GLP-1 prescriptions; asked committee to pass the bill for a fair, transparent reimbursement floor.

### Hearing clips

[

![Hearing clip: AZ (HB2196: Rep. Bliss (against)) PBM reimbursement floor](https://app.uslege.ai/api/clip-thumbnail/1610ed1d-61f9-4717-8bb8-435c5028737e)▶

AZ (HB2196: Rep. Bliss (against)) PBM reimbursement floor

Rep. Selina Bliss (R), Arizona House Health & Human Services Cmte · 3133-3205

“If a pharmacy is not owned or operated by a PBM, then the pharmacy benefit's manager cannot reimburse them for less than what the drug actually costs them. So that's what this bill is for. It's only fair in a competitive market.”

Watch clip

](https://app.uslege.ai/share/1610ed1d-61f9-4717-8bb8-435c5028737e?from=clips)[

![Hearing clip: AZ (HB2196: Kelsey Lundy/PCMA (for)) "cost shift...to benefit one industry"](https://app.uslege.ai/api/clip-thumbnail/45948edd-6a68-4f7f-a3e5-744cda1e3d45)▶

AZ (HB2196: Kelsey Lundy/PCMA (for)) "cost shift...to benefit one industry"

Kelsey Lundy, Pharmaceutical Care Management Association (PCMA) · 3213-3325

“That is a cost shift from every Arizonan who is paying for health insurance to benefit one industry, which would be pharmacy.”

Watch clip

](https://app.uslege.ai/share/45948edd-6a68-4f7f-a3e5-744cda1e3d45?from=clips)

#10 of 48

#10

## Connecticut

Restrictive

Connecticut legislators filed a dense slate of PBM-reform bills in 2025: a fiduciary-style duty of good faith (SB820), rebate/point-of-sale pass-through mandates (SB1011, SB1012), and two comprehensive reform-and-AG-oversight bills (SB821, SB758): but all stalled in the Insurance & Real Estate committee. In 2026, SB342 (anti-steering, mail-order-mandate ban, 30-day step-therapy cap) reached the House calendar and HB5375 (mandating pharmacist network inclusion/reimbursement) was signed into law, showing reform pressure converting into real mandates.

Freedom from Comprehensive Reform8/25

Few PBM Mandates10/20

Light Enforcement / No Fiduciary Duty8/20

Business-Model Freedom8/20

Limited Regulatory Reach6/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

Martin M. Looney

D

SB 820

Sponsored a bill imposing a fiduciary-style duty of good faith on PBMs toward carriers, pharmacies, and patients (stalled in committee).

Heather Somers

R

SB 1011

Sponsored a point-of-sale rebate pass-through mandate for PBMs (stalled in committee).

Henri Martin

R

SB 821

Sponsored comprehensive PBM reform banning clawback fees and decoupling PBM pay from drug cost, with AG price-gouging oversight (stalled).

Saud Anwar

D

SB 758

Sponsored comprehensive PBM reform establishing an AG-enforced duty of care and rebate transparency mandate (stalled).

Jonathan Steinberg

D

HB 6814

Sponsored a PBM contract-limitation/transparency reform bill (stalled in committee).

**Why it matters:** Connecticut is a rising-risk state: no comprehensive PBM law is on the books yet, but bipartisan reform bills keep advancing and one narrow mandate just became law: the fiduciary-duty and rebate-pass-through bills are likely to resurface next session.

### Bills

SB 820An Act Establishing a Duty of Good Faith and Fair Dealing Owed by Pharmacy Benefits ManagersRestrictive

Would establish a legal duty of good faith and fair dealing for PBMs toward health carriers, plan sponsors, pharmacies, and covered persons, mandating ethical, transparent, and equitable conduct across the pharmacy benefit supply chain.

**Sponsor:** Martin M. Looney (D)**Status:** Stalled in committee, 2025 session**Category:** Fiduciary-style duty (stalled)

[View on USLege →](https://app.uslege.ai/bills/2301084)

SB 1011An Act Regulating Rebates by Pharmacy Benefits ManagersRestrictive

Would require PBMs to calculate enrollee cost-sharing at the point of sale based on net price after rebates, and to certify compliance with this method to the Insurance Department.

**Sponsor:** Heather Somers (R)**Status:** Stalled in committee, 2025 session**Category:** Rebate pass-through mandate (stalled)

[View on USLege →](https://app.uslege.ai/bills/2301297)

SB 821An Act Concerning Pharmacy Benefits Manager Reform and Price Gouging in the Health Care SectorRestrictive

Would prohibit PBM fees and clawbacks, mandate rebate/administrative-cost transparency, unlink PBM compensation from drug costs, prevent favoring costlier drugs, and give the Attorney General price-gouging oversight authority.

**Sponsor:** Henri Martin (R)**Status:** Stalled in committee, 2025 session**Category:** Comprehensive reform (stalled)

[View on USLege →](https://app.uslege.ai/bills/2301088)

SB 758An Act Concerning Pharmacy Benefits Manager ReformRestrictive

Would prohibit certain PBM fees and clawbacks, mandate rebate transparency/passthrough, decouple compensation from drug cost, require GPO fee disclosure, and establish a PBM duty of care enforced by the Attorney General.

**Sponsor:** Saud Anwar (D)**Status:** Stalled in committee, 2025 session**Category:** Comprehensive reform + AG oversight (stalled)

[View on USLege →](https://app.uslege.ai/bills/2301095)

HB 6814An Act Concerning Pharmacy Benefits Manager ReformRestrictive

Would impose limitations on PBM contracts to reduce consumers' out-of-pocket expenses and enhance transparency in PBM operations under Title 38a.

**Sponsor:** Jonathan Steinberg (D)**Status:** Stalled in committee, 2025 session**Category:** Contract limitation/transparency (stalled)

[View on USLege →](https://app.uslege.ai/bills/2299670)

SB 342An Act Concerning Health CoverageRestrictive

Restricts anti-steering clauses and automatic downcoding without clinical review, sets a 30-day cap on step therapy for certain serious conditions, and bans mail-order pharmacy mandates.

**Sponsor:** Insurance and Real Estate Committee**Status:** Advancing: House Calendar No. 575 (2026-05-06)**Category:** Anti-steering / step-therapy limits (advancing)

[View on USLege →](https://app.uslege.ai/bills/3855936)

HB 5375An Act Concerning the Recommendations of the Insurance and Real Estate Committee Working GroupsRestrictive

Mandates health carriers include pharmacists in provider networks and reimburse them for covered clinical services within their licensed scope, similarly to other healthcare providers.

**Sponsor:** Insurance and Real Estate Committee**Status:** Signed by the Governor (2026-05-27)**Category:** Pharmacist network/reimbursement mandate (enacted)

[View on USLege →](https://app.uslege.ai/bills/3855839)

### Hearing clips

No clip available. Connecticut's legislative video is copyrighted or restricted by state law. No on-topic PBM-reform testimony exists on the record for SB 820 in any case: the state's adjacent Human Services, Nominations and Labor hearings contain none.

#11 of 48

#11

## Wisconsin

Restrictive

Wisconsin's marquee comprehensive PBM bill, AB 173/SB 203, carries broad bipartisan cosponsorship and would mandate minimum dispensing fees, ban certain PBM-to-pharmacy fees, require MAC-list transparency, equalize network reimbursement, protect 340B entities, impose annual PBM financial disclosure, extend fiduciary duty to plan sponsors, and limit formulary changes -- but as of Feb 2026 it remains in committee, not enacted. SB 50/AB 62 (health care costs omnibus) would layer on PSAO licensure and further PBM fiduciary/disclosure duties but has stalled since February 2025. Narrower bills are moving: AB 127/SB 137 bars PBMs from penalizing pharmacies for off-label dispensing, AB 714 gives plan sponsors ownership/access rights to PBM claims data, and AB 1170 mandates manufacturer drug-price reporting.

Freedom from Comprehensive Reform8/25

Few PBM Mandates8/20

Light Enforcement / No Fiduciary Duty8/20

Business-Model Freedom8/20

Limited Regulatory Reach8/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

Todd Novak

R

AB 173

Lead sponsor of the comprehensive PBM dispensing-fee, transparency, and fiduciary-duty regulation bill.

Mary Felzkowski

R

SB 203

Lead Senate sponsor of the comprehensive PBM regulation bill.

Brad Pfaff

D

SB 50

Sponsored the health care costs omnibus imposing PBM fiduciary/disclosure duties and PSAO licensure.

David Murphy

R

AB 127

Sponsored the bill barring PBMs from penalizing pharmacies for off-label dispensing.

Robert Wittke

R

AB 714

Sponsored the bill forcing PBMs to cede claims-data ownership and access rights to plan sponsors.

Ann Roe

D

AB 1170

Sponsored the drug-pricing transparency reporting mandate.

**Why it matters:** No PBM law has been enacted yet in Wisconsin, but AB 173/SB 203's wide bipartisan coalition (18+ Senate cosponsors across both parties) signals this is likely to move -- it stands as the leading reform vehicle before it reaches a floor vote, while AB 714's claims-data-ownership bill quietly erodes PBM data control in the meantime.

### Bills

AB 173Regulation of pharmacy benefit managers, fiduciary and disclosure requirementsRestrictive

Mandates minimum dispensing fees, prohibits certain PBM-to-pharmacy fees, requires MAC-list transparency, equalizes network reimbursement, protects 340B entities, mandates annual PBM financial disclosure, extends fiduciary duty to plan sponsors, tightens audit rules, and limits formulary changes.

**Sponsor:** Todd Novak (R)**Status:** In committee (pending), 2025-26 session -- coauthor added Feb. 2026**Category:** Comprehensive PBM regulation

[View on USLege →](https://app.uslege.ai/bills/2290120)

SB 203Regulation of pharmacy benefit managers, fiduciary and disclosure requirementsRestrictive

Senate companion to AB 173, carrying identical comprehensive PBM dispensing-fee, transparency, fiduciary-duty, audit, and formulary provisions, cosponsored across both parties.

**Sponsor:** Mary Felzkowski (R)**Status:** In committee (pending), 2025-26 session**Category:** Comprehensive PBM regulation

[View on USLege →](https://app.uslege.ai/bills/2290694)

SB 50Health care costs omnibusRestrictive

Eliminates Medicaid Rx cost-sharing, caps insulin cost-sharing, imposes fiduciary/disclosure duties on PBMs, licenses pharmacy services administrative organizations, and creates drug-importation and value-based pricing programs.

**Sponsor:** Brad Pfaff (D)**Status:** Referred to Committee on Health (pending), 2025-26 session**Category:** Omnibus incl. PBM fiduciary/disclosure + PSAO licensure

[View on USLege →](https://app.uslege.ai/bills/2290525)

AB 127The duty of a pharmacist to dispense lawfully prescribed drugs and devicesRestrictive

Expands pharmacists' duty to dispense lawfully prescribed drugs and prohibits PBMs from penalizing pharmacies for dispensing drugs prescribed for off-label uses.

**Sponsor:** David Murphy (R)**Status:** Fiscal estimate received (pending), 2025-26 session**Category:** Anti-retaliation / off-label dispensing protection

[View on USLege →](https://app.uslege.ai/bills/2290121)

AB 714Plan sponsors' right to access claims dataRestrictive

Requires PBM/insurer/administrator contracts with large-group plan sponsors to recognize the sponsor as owner of claims data, mandate timely access to payments/fees/rebates, and restrict PBM resale of claims data.

**Sponsor:** Robert Wittke (R)**Status:** Referred to Committee on Insurance (pending), 2025-26 session**Category:** Plan-sponsor claims-data rights

[View on USLege →](https://app.uslege.ai/bills/3372865)

AB 1170Prescription drug cost reporting by manufacturersRestrictive

Requires manufacturers to report significant price increases and high-cost drug launches with justifications, and mandates annual disclosure of price concessions and assistance-program terms to state officials.

**Sponsor:** Ann Roe (D)**Status:** Failed to pass (Senate Joint Resolution 1), March 2026: dead this session**Category:** Drug-pricing transparency mandate

[View on USLege →](https://app.uslege.ai/bills/3866943)

### Hearing clips

No clip available. No hearing or committee video exists for AB 173/SB 203, or for any other Wisconsin PBM bill, in the 2025–26 window. Both bills remain in committee and neither received video-recorded proceedings.

#12 of 48

#12

## Massachusetts

Restrictive

No comprehensive PBM law is enacted, but the pipeline is dense and moving: H.1234 (rebate pass-through, spread-pricing ban) and H.4488 (MAC/reimbursement, PBM-affiliate parity) were both reported favorably by committee in Sept. 2025, and three separate PBM fiduciary-duty bills (H.1334, H.1167, H.1082) remain alive via repeated reporting-date extensions through July 2026 rather than dying. No enabling/deregulatory PBM bill was found.

Freedom from Comprehensive Reform8/25

Few PBM Mandates9/20

Light Enforcement / No Fiduciary Duty7/20

Business-Model Freedom8/20

Limited Regulatory Reach6/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

John Lawn

D · Dist. MA House

H.1234

Prime sponsor of the 80% rebate pass-through / spread-pricing ban bill reported favorably by committee.

James Murphy

D · Dist. MA House

H.4488

Prime sponsor of the MAC-list reimbursement and PBM-affiliate parity bill reported favorably by committee.

Paul Feeney

D · Dist. MA Senate

H.4488

Co-prime-sponsor of the MAC-list reimbursement bill.

Chynah Tyler

D · Dist. MA House

H.1334

Sponsor of the PBM fiduciary-duty and spread-pricing-ban bill.

Alyson Sullivan-Almeida

R · Dist. MA House

H.1330

Republican sponsor of a MAC-transparency/appeal bill later folded into H.4488, showing bipartisan reform interest.

**Why it matters:** MA is an active-reform state: multiple committee-advanced bills (rebate pass-through, MAC reimbursement floors, fiduciary duty, spread-pricing bans) are still procedurally alive, not dead, and could be combined into a comprehensive PBM Act if any clears House Ways and Means.

### Bills

H.1234An Act relative to pharmacy benefit managersRestrictive

Establishes comprehensive PBM regulations mandating carriers/PBMs pass at least 80% of estimated rebates to insureds via reduced cost-sharing, imposes a duty of good faith, network adequacy standards, pharmacy reimbursement protections, and bans spread pricing and unjust fees, with periodic audits and a grievance process.

**Sponsor:** John Lawn (D–MA House (district not published by USLege))**Status:** Reported favorably by committee, referred to House Ways and Means (2025-09-18)**Category:** Rebate pass-through / spread pricing

[View on USLege →](https://app.uslege.ai/bills/2250985)

H.4488An Act relative to pharmacy benefit managers reimbursements to pharmacies in the CommonwealthRestrictive

Imposes strict rules on PBM Maximum Allowable Cost (MAC) drug lists, requires equivalency/availability criteria and timely transparent updates, creates an administrative appeal process for pharmacies challenging reimbursement, and bars PBMs from reimbursing pharmacies less than PBM-owned affiliates; applies to MassHealth and GIC PBMs too.

**Sponsor:** James Murphy (D–MA House (district not published by USLege))**Status:** Reported favorably by committee (2025-09-18); reporting date extended to July 31, 2026**Category:** MAC list / reimbursement

[View on USLege →](https://app.uslege.ai/bills/2256661)

H.1334An Act to enact pharmacy benefit manager dutiesRestrictive

Creates new Chapter 175N imposing explicit duties on PBMs to act with care, fairness and transparency and in the best interests of enrollees, plans and providers; mandates conflict-of-interest and pricing disclosure and prohibits spread pricing, enforced by the insurance commissioner.

**Sponsor:** Chynah Tyler (D–MA House (district not published by USLege))**Status:** Pending in Financial Services; reporting date extended to July 31, 2026**Category:** Fiduciary duty

[View on USLege →](https://app.uslege.ai/bills/2252168)

H.1167An Act to enact pharmacy benefit manager dutiesRestrictive

Establishes fiduciary duties and regulatory standards for PBMs focused on care, transparency and fairness to enrollees, plans and providers; mandates pricing/conflict-of-interest transparency with regulatory enforcement authority.

**Sponsor:** Sean Garballey (D–MA House (district not published by USLege))**Status:** Pending in Financial Services; reporting date extended to July 31, 2026**Category:** Fiduciary duty

[View on USLege →](https://app.uslege.ai/bills/2250735)

H.1082An Act to enact the pharmacy benefit manager compensation reformRestrictive

Restricts PBM compensation solely to transparent pharmacy-benefit-management fees, prohibits spread pricing, mandates annual compliance certification and audits, requires detailed contract disclosures.

**Sponsor:** Bruce Ayers (D–MA House (district not published by USLege))**Status:** Pending in Financial Services; reporting date extended to July 31, 2026**Category:** PBM compensation reform

[View on USLege →](https://app.uslege.ai/bills/2252072)

H.1330An Act relative to pharmacy benefit managers reimbursements to pharmacies in the CommonwealthRestrictive

Establishes MAC-list transparency requirements and a pharmacy appeal mechanism for reimbursement below acquisition cost; folded into H.4488, which a Republican member also co-sponsored.

**Sponsor:** Alyson Sullivan-Almeida (R–MA House (district not published by USLege))**Status:** Superseded: accompanied a new draft, see H.4488 (2025-09-18)**Category:** MAC list / reimbursement

[View on USLege →](https://app.uslege.ai/bills/2252290)

### Who testified: stakeholders on the record · 2 on the record

### Testified FOR PBMs (against new regulation) · for

No witnesses testified in support on the record.

### Testified AGAINST PBMs (for reform) · against

Dave Morgan

Pharmacy consultant; past president, Massachusetts Pharmacists Association; former owner of five Boston-area pharmacies

H.1326

40-year pharmacist testified that PBMs CVS Caremark, Optum Rx and Express Scripts are an oligopoly controlling 80% of the U.S. prescription market and 100% of Medicare scripts in MA, reimburse many independents below cost (up to 70% of fills at a loss), and are driving closures (cited his own longtime pharmacy, Olsen's in Weymouth); urged passage of H.1326's MassHealth MCO/ACO fair-reimbursement and MAC-transparency mandate.

Dennis Lyons

Massachusetts Independent Pharmacies

H.1326

Appeared alongside Dave Morgan in support of H.1326, adding that PBMs are agents of insurers and that taxpayer MassHealth dollars now routed through for-profit PBMs could instead be managed in-house by the state.

### Hearing clips

No clip available. No Massachusetts hearing video carries PBM content for H.1234 or H.4488. The Joint Financial Services videos covering September 2025 (when both bills were reported favorably) and the current-session Ways & Means videos contain none, and the hearing at which the bills were actually taken up is not in the platform's video record.

#13 of 48

#13

## New Mexico

Restrictive

New Mexico has enacted narrower but real PBM-constraining mandates even though its two comprehensive PBM bills failed: HB 174 (2025, enacted) sets a mandated NADAC/WAC-plus-dispensing-fee reimbursement floor for Health Care Purchasing Act plans, and SB 39 (2025) / SB 20 (2026) (both enacted) strip PBMs of prior-authorization and step-therapy gatekeeping on broad drug classes. A mandated reimbursement floor is one of the rubric's core hard-reform criteria and was enacted, not merely proposed, so it should weigh more than a state with zero enacted mandates.

Freedom from Comprehensive Reform8/25

Few PBM Mandates9/20

Light Enforcement / No Fiduciary Duty8/20

Business-Model Freedom8/20

Limited Regulatory Reach5/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

Elizabeth Stefanics

D · Dist. 39

SB 20

Sponsored two enacted bills (SB 39, SB 20) stripping PBM prior-authorization/step-therapy tools.

Larry Scott

R · Dist. 42

SB 503

Sponsored anti-steering/spread-pricing ban targeting PBMs (failed but on record).

Gail Armstrong

R · Dist. 49

HB 174

Sponsored the enacted pharmacy reimbursement-floor mandate that caps PBM/plan flexibility on pharmacy pay.

**Why it matters:** In NM the comprehensive PBM bill has failed twice, but drip-feed reimbursement-floor and prior-authorization restrictions are still being enacted piecemeal, eroding utilization-management tools without a single omnibus fight to focus attention on.

### Bills

SB 62Pharmacy Benefit Manager FeesRestrictive

Amends the PBM Regulation Act to define and restrict fees PBMs can collect, broaden definitions of PBM activities/affiliates, and strengthen licensing and enforcement including penalties for conflicts of interest and unfair trade practices.

**Sponsor:** Elizabeth Stefanics (D–39)**Status:** Action Postponed Indefinitely (failed), 2025 session**Category:** PBM fee restrictions

[View on USLege →](https://app.uslege.ai/bills/2218896)

SB 503Prohibit Certain Pharmacy Benefits Mgr. ActsRestrictive

Prohibits PBM patient-steering and spread pricing, requires contract transparency, and lets pharmacies share cost information with patients, with enhanced reporting requirements.

**Sponsor:** Larry Scott (R–42)**Status:** Action Postponed Indefinitely (failed), 2025 session**Category:** Anti-steering / spread-pricing ban

[View on USLege →](https://app.uslege.ai/bills/2219390)

HB 174Pharmacy Reimbursement For Certain PlansRestrictive

Mandates Health Care Purchasing Act plans reimburse community-based pharmacies at least NADAC/WAC plus a professional dispensing fee no less than Medicaid fee-for-service pays.

**Sponsor:** Gail Armstrong (R–49)**Status:** Signed by Governor - Chapter 33, Apr. 7, 2025 (enacted)**Category:** Mandated reimbursement floor

[View on USLege →](https://app.uslege.ai/bills/2214151)

SB 39Add Classes To Prior Authorization DrugsRestrictive

Expands prior-authorization/step-therapy exemptions to autoimmune, cancer, rare-disease and substance-use-disorder drug classes and mandates electronic PBM/insurer prior-auth systems with hard approval timelines.

**Sponsor:** Elizabeth Stefanics (D–39)**Status:** Signed by Governor - Chapter 57, Apr. 7, 2025 (enacted)**Category:** Prior-authorization restriction

[View on USLege →](https://app.uslege.ai/bills/2218876)

SB 20Prior Authorization & Prescription DrugsRestrictive

Extends the Prior Authorization Act explicitly to PBMs contracted under the Health Care Purchasing Act, standardizes their prior-authorization processes, and limits reauthorization frequency for chronic maintenance drugs.

**Sponsor:** Elizabeth Stefanics (D–39)**Status:** Signed by Governor - Chapter 47, Mar. 6, 2026 (enacted)**Category:** PBM utilization-management restriction

[View on USLege →](https://app.uslege.ai/bills/3822978)

### Who testified: stakeholders on the record · 5 on the record

### Testified FOR PBMs (against new regulation) · for

Pat Block

Otero Consulting, registered lobbyist for Prime Therapeutics (PBM owned by 19 nonprofit Blue Cross Blue Shield plans)

SB 20

Testified in opposition to SB 20 as drafted, raising patient-safety concerns about the bill's three-year prior-authorization limitation for PBM-managed drug approvals.

### Testified AGAINST PBMs (for reform) · against

Ashley Seifarth

Owner, Care Drug pharmacy (Bloomfield/Aztec, NM)

HB 174

Testified that current Health Care Purchasing Act reimbursement is 'absolutely killing' her pharmacy (running $30,000 in the hole on ingredient cost alone), urging passage of the NADAC-plus-dispensing-fee reimbursement floor to keep the only pharmacy in her rural town open.

John Thompson

Registered lobbyist, New Mexico Pharmacy Business Council

HB 174

Testified the bill is a 'break-even' measure needed to keep the state's roughly 55 remaining community pharmacies (down from 125) financially viable under state-employee/retiree plan reimbursement.

Lex Garcia

Pharmacist; Executive Director, New Mexico Pharmacists Association

HB 174

Testified in strong support, framing inadequate PBM/plan reimbursement as both a health-care and economic-development problem causing pharmacy closures and 'pharmacy deserts' across the state.

Kirk Erby

Owner, Lowell's Pharmacy (Artesia, NM)

HB 174

Testified in support, corroborating Seifarth's account of unsustainable reimbursement at his own independent pharmacy.

### Hearing clips

[

![Hearing clip: NM: SB 20: Pat Block, Prime Therapeutics/PCMA-member lobbyist (for)](https://app.uslege.ai/api/clip-thumbnail/407a87ba-fd3b-4613-82e9-b0090448d85d)▶

NM (SB 20: Pat Block, Prime Therapeutics/PCMA-member lobbyist (for)

Pat Block, Otero Consulting) registered lobbyist for Prime Therapeutics (a PBM owned by 19 Blue Cross Blue Shield plans) · 1115-1225

“We are here tonight to respectfully oppose Senate Bill 20 as drafted... This bill does not include important exceptions for safety... It should be limited to one year. More regular monitoring aligns to the standards of care.”

Watch clip

](https://app.uslege.ai/share/407a87ba-fd3b-4613-82e9-b0090448d85d?from=clips)

Only one clippable on-topic hearing found for this state; a second real clip was not available (no other on-topic hearing or opposition testimony).

#14 of 48

#14

## Michigan

Restrictive

Michigan's standing law is **Public Act 11 of 2022** (companion PA 12 of 2022), the Pharmacy Benefit Manager Licensure and Regulation Act, which took effect January 1, 2024. It requires every PBM operating in Michigan to hold a biennial license from DIFS, imposes a statutory good-faith-and-fair-dealing duty toward health plans and network pharmacies (a contract provision waiving it is void by statute), bars discrimination against non-affiliated retail pharmacies, and empowers the Director to fine, suspend, or revoke a PBM's license. That is an enacted, statewide licensure-and-enforcement regime: short of a spread-pricing ban or a full fiduciary duty, but well beyond light-touch.

Freedom from Comprehensive Reform9/25

Few PBM Mandates7/20

Light Enforcement / No Fiduciary Duty7/20

Business-Model Freedom6/20

Limited Regulatory Reach5/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

Alabas Farhat

D · Dist. House 3

HB 5303

Sponsor of the Medicaid-managed-care PBM reimbursement-floor mandate for small pharmacies.

Carrie Rheingans

D · Dist. House (district not confirmed)

HB 6212

Sponsor of the copay-accumulator ban restricting PBM/insurer cost-sharing calculations.

**Why it matters:** Michigan is comparatively light-touch for PBMs today: no core PBM statute is at serious risk this session. HB 5303 (Medicaid PBM reimbursement mandate) and HB 6212 (copay accumulator ban) are worth monitoring, since either could become a vehicle for broader PBM restrictions if amended.

### Bills

HB 5303Medicaid managed care contract with pharmacy benefit manager; modify reimbursementRestrictive

Bars the state from contracting with Medicaid MCOs whose PBMs fail to meet reimbursement standards for small Michigan pharmacies (7 or fewer outlets); sets brand/generic reimbursement methodology and bars PBMs from retaining professional dispensing-fee amounts.

**Sponsor:** Alabas Farhat (D–House 3)**Status:** Introduced 2025-12-02, referred to Committee on Health Policy**Category:** Mandated reimbursement floor

[View on USLege →](https://app.uslege.ai/bills/3359955)

HB 6212Health benefits; application of amounts paid toward insured's co-payRestrictive

Requires health plans with drug coverage to count amounts paid by the enrollee or third parties toward out-of-pocket maximums/cost-sharing, effectively banning copay accumulator programs, with HSA-compatibility carve-outs.

**Sponsor:** Carrie Rheingans (D–House (district not confirmed))**Status:** Introduced 2026-07-03, electronically reproduced**Category:** Copay accumulator ban

[View on USLege →](https://app.uslege.ai/bills/3888533)

SB 3Prescription drug cost and affordability review act; createMixed-Monitor

Creates a Prescription Drug Affordability Board and stakeholder council empowered to review costs of high-cost drugs and set upper payment limits; targets drug manufacturers/plan costs generally rather than PBM contracting practices specifically.

**Sponsor:** Darrin Camilleri (D–Senate 4)**Status:** Passed the Michigan Senate (2025-04-24)**Category:** Drug affordability board

[View on USLege →](https://app.uslege.ai/bills/2244098)

HB 4544Prescription drug cost and affordability review act; create (companion)Mixed-Monitor

House companion to SB 3 establishing the same Prescription Drug Affordability Board and upper-payment-limit authority for high-cost drugs.

**Sponsor:** Matt Longjohn (D–House (district not confirmed))**Status:** Introduced 2025-06-03, stalled**Category:** Drug affordability board

[View on USLege →](https://app.uslege.ai/bills/2243332)

HB 6132Insulin drug pricing report by the Attorney GeneralMixed-Monitor

Directs the Michigan AG to investigate insulin pricing and business practices statewide and issue a policy-recommendation report by Oct. 2027; a study mandate, not a binding PBM restriction.

**Sponsor:** Jennifer Conlin (D–House (district not confirmed))**Status:** Introduced 2026-06-25, electronically reproduced**Category:** Transparency study

[View on USLege →](https://app.uslege.ai/bills/3886594)

HB 4878340B program reporting and manufacturer conductMixed-Monitor

Bars manufacturers/distributors from restricting 340B drug acquisition and adds reporting duties on 340B hospitals and manufacturers' price increases; aimed at manufacturer conduct, only tangential to PBM contracting.

**Sponsor:** Curtis VanderWall (R–House (district not confirmed))**Status:** Recommendation concurred in (2026-01-28): narrow, partial advancement**Category:** 340B protection

[View on USLege →](https://app.uslege.ai/bills/2243667)

### Who testified: stakeholders on the record · 2 on the record

### Testified FOR PBMs (against new regulation) · for

Sean Stephenson

Senior Director of State Affairs, Pharmaceutical Care Management Association (PCMA)

PBM Licensure & Regulation Act oversight (PA 11/12 of 2022)

Defended PBMs at the same House Oversight Subcommittee hearing, arguing PBMs will save Michiganders $42.3B over ten years, that independent-pharmacy counts are stable, and that Michigan already has 21+ PBM laws on the books; urged the committee to 'push the brakes on anything further' rather than add a dispensing-fee floor or other new mandates.

### Testified AGAINST PBMs (for reform) · against

Eric Groth

Director of Government Affairs, Michigan Pharmacists Association

PBM Licensure & Regulation Act oversight (PA 11/12 of 2022)

Testified at a House Oversight Subcommittee hearing on pharmacy closures that DIFS has interpreted Michigan's 2022 PBM law so narrowly that clawbacks routed through PSAOs, fraud/abuse audit exceptions, and ERISA carve-outs let PBMs continue harmful practices; walked through a documented 11-month, $11k-to-$33k recoupment case and urged the legislature to close the loopholes and give DIFS stronger enforcement authority.

### Hearing clips

[

![Hearing clip: MI (PBM Oversight Hearing: Sean Stephenson (PCMA) (for)) Why states hire PBMs](https://app.uslege.ai/api/clip-thumbnail/5e40f7c4-6be2-428b-9c9f-bce1fd53d395)▶

MI (PBM Oversight Hearing: Sean Stephenson (PCMA) (for)) Why states hire PBMs

Sean Stephenson, Senior Director of State Affairs, Pharmaceutical Care Management Association · 2178-2325

“We're hired by employers, unions, governments, like the state of Michigan, and others to drive down prescription drug costs.”

Watch clip

](https://app.uslege.ai/share/5e40f7c4-6be2-428b-9c9f-bce1fd53d395?from=clips)[

![Hearing clip: MI (PBM Oversight Hearing: Monique Whitney (PUTT) (against)) PBM opacity enables outsized profits](https://app.uslege.ai/api/clip-thumbnail/4442ebcb-a1c6-4fbd-94aa-609c57bfa346)▶

MI (PBM Oversight Hearing: Monique Whitney (PUTT) (against)) PBM opacity enables outsized profits

Monique Whitney, Executive Director, Pharmacists United for Truth and Transparency (PUTT) · 630-776

“PBMs can and do provide a real service, but decades of opacity and complexity by design have made it difficult... to rein in some of the activities that allow PBMs to reap outsized profits.”

Watch clip

](https://app.uslege.ai/share/4442ebcb-a1c6-4fbd-94aa-609c57bfa346?from=clips)

#15 of 48

#15

## New Jersey

Restrictive

New Jersey is running the most comprehensive PBM-reform pipeline in this group. The Patient and Provider Protection Act (S2345/A1502) would impose a fiduciary duty on PBMs and mandate fair pharmacy reimbursement: and A1502 has already cleared the Assembly and was received in the Senate (Senate Commerce Committee, 5/18/2026), the only bill in this set to pass a full chamber. Alongside it: an outright spread-pricing ban with full rebate pass-through (S4208/A5020); a compliance-unit-backed Pharmacy Fair Reimbursement & Anti-Steering Act (S3212); a PBM-owned-pharmacy ownership ban (A4948); bona-fide-service-fee compensation mandates (S4205/A5019); a Medicaid NADAC-plus-dispensing-fee reimbursement floor (S2621); and an audit/payment-timeline transparency bill (S464). None have reached the Governor's desk this session (several are repeat filings of bills that also failed to advance in the 2024-2025 session) but the sheer breadth and A1502's chamber passage signal serious momentum.

Freedom from Comprehensive Reform10/25

Few PBM Mandates7/20

Light Enforcement / No Fiduciary Duty6/20

Business-Model Freedom6/20

Limited Regulatory Reach4/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

Troy Singleton

Democratic

S 3212

Sponsored the comprehensive anti-steering/fair-reimbursement act with a dedicated compliance and enforcement unit.

Roy Freiman

Democratic

A 1502

Sponsored the fiduciary-duty Patient and Provider Protection Act, the only bill in this set to pass a full chamber (Assembly).

John McKeon

Democratic

S 2345

Sponsored the Senate fiduciary-duty companion bill for PBMs.

Raj Mukherji

Democratic

S 4208

Sponsored the Senate spread-pricing ban with full rebate pass-through.

Luanne Peterpaul

Democratic

A 5020

Sponsored the Assembly companion spread-pricing ban.

Margie Donlon

Democratic

A 4948

Sponsored the bill barring PBMs from owning pharmacy practice sites.

Vin Gopal

Democratic

S 2621

Sponsored the Medicaid reimbursement-floor and pharmacy-choice mandate.

Brian Stack

Democratic

S 464

Sponsored the PBM audit and payment-timeline transparency bill.

**Why it matters:** New Jersey carries the highest near-term legislative activity in this group: a fiduciary-duty bill has already passed one chamber, and a stacked pipeline of spread-pricing bans, reimbursement floors, and ownership restrictions sits directly behind it.

### Bills

S 3212Pharmacy Fair Reimbursement & Anti-Steering ActRestrictive

Mandates detailed PBM data reporting, prohibits spread pricing, enforces pass-through pricing in state health programs, ensures fair pharmacy reimbursement, protects against abusive audits, creates a consumer drug-price comparison tool, guarantees geographic pharmacy access, and establishes a compliance and enforcement unit.

**Sponsor:** Troy Singleton (Democratic)**Status:** Introduced, Referred to Senate Commerce Committee (1/28/2026)**Category:** Comprehensive anti-steering / reimbursement reform

[View on USLege →](https://app.uslege.ai/bills/3814898)

A 1502Patient and Provider Protection ActRestrictive

Establishes fiduciary duties for PBMs to act in the best interest of carriers, prohibits misleading marketing, mandates fair pharmacy reimbursement rates, forbids rebate conditions that exclude generics, and requires equitable formulary tiering favoring lower-cost generics and biosimilars.

**Sponsor:** Roy Freiman (Democratic)**Status:** Passed Assembly; Received in Senate, Referred to Senate Commerce Committee (5/18/2026)**Category:** PBM fiduciary duty

[View on USLege →](https://app.uslege.ai/bills/3826599)

S 2345Patient and Provider Protection ActRestrictive

Senate companion imposing fiduciary duties focused on long-term health outcomes, restricting certain PBM contract practices, ensuring fair pharmacy reimbursement, and mandating transparent flat-fee PBM compensation.

**Sponsor:** John McKeon (Democratic)**Status:** Introduced in the Senate, Referred to Senate Commerce Committee (1/13/2026)**Category:** PBM fiduciary duty

[View on USLege →](https://app.uslege.ai/bills/3814031)

S 4208Pharmacy benefit manager-prohibit using spread pricing as model of drug pricingRestrictive

Prohibits PBMs from using spread pricing, requires remittance of all rebates/fees/remuneration to health plans, mandates audited financial statement submission to Banking and Insurance, and requires annual public reporting on PBM compensation and pricing practices.

**Sponsor:** Raj Mukherji (Democratic)**Status:** Introduced in the Senate, Referred to Senate Commerce Committee (5/11/2026)**Category:** Spread-pricing ban

[View on USLege →](https://app.uslege.ai/bills/3878989)

A 5020Pharmacy benefit manager-prohibit using spread pricing as model of drug pricingRestrictive

Assembly companion to S4208 prohibiting PBM spread pricing statewide and mandating full rebate/fee pass-through plus audited financial and public compensation reporting.

**Sponsor:** Luanne Peterpaul (Democratic)**Status:** Introduced, Referred to Assembly Financial Institutions and Insurance Committee (5/7/2026)**Category:** Spread-pricing ban

[View on USLege →](https://app.uslege.ai/bills/3879013)

A 4948Pharmacy benefit managers-prohibit operating practice sites directly or indirectlyRestrictive

Prohibits PBMs from owning or operating pharmacy practice sites in New Jersey effective July 1, 2027, authorizing the State Board of Pharmacy to revoke or deny permits to violating pharmacies, with limited exceptions for rare/orphan-drug dispensing.

**Sponsor:** Margie Donlon (Democratic)**Status:** Introduced, Referred to Assembly Financial Institutions and Insurance Committee (5/7/2026)**Category:** PBM-pharmacy ownership ban

[View on USLege →](https://app.uslege.ai/bills/3878854)

S 2621Equitable Drug Pricing and Patient Access ActRestrictive

Mandates Medicaid pharmacy reimbursement at no less than national average acquisition cost plus a professional dispensing fee, guarantees Medicaid managed-care pharmacy choice without cost-based restriction, and requires a State Auditor review of Medicaid pharmacy pricing and fund flows.

**Sponsor:** Vin Gopal (Democratic)**Status:** Introduced in the Senate, Referred to Senate Health, Human Services and Senior Citizens Committee (1/13/2026)**Category:** Reimbursement floor / pharmacy choice

[View on USLege →](https://app.uslege.ai/bills/3814307)

S 464Pharmacy benefit managers-establish audit & payment requirementsRestrictive

Requires detailed PBM contract disclosures, 14-day claim payment/contestation timelines, internal dispute resolution and arbitration, annual Department of Banking and Insurance audits, weekly pricing updates, and records access for inspection.

**Sponsor:** Brian Stack (Democratic)**Status:** Introduced in the Senate, Referred to Senate Commerce Committee (1/13/2026)**Category:** PBM audit & payment transparency

[View on USLege →](https://app.uslege.ai/bills/3812153)

### Who testified: stakeholders on the record · 4 on the record

### Testified FOR PBMs (against new regulation) · for

Matt Greller

Solo-practitioner lobbyist representing the Pharmaceutical Care Management Association (PCMA)

A 1502

Strongly opposed the bill, arguing it undoes New Jersey's 2023 PBM transparency law before it could take effect, that rebates lower rather than raise costs, that fiduciary duty would weaken PBM negotiating leverage, and that the added NADAC-plus-dispensing-fee reimbursement floor amounts to an '$11 pill tax.'

Marcus Caruso

PBM industry representative (employer not stated on record)

A 1502

Opposed the bill, defending PBM rebate negotiation as lowering net costs, calling the 'contract of adhesion' framing between PBMs and pharmacies misleading given PSAO bargaining power, and warning the NADAC-plus-dispensing-fee floor would raise patient point-of-sale costs.

Ward Sanders

New Jersey Association of Health Plans

A 1502

While agreeing prescription drug costs need addressing, raised concerns on behalf of health plans about the bill's reimbursement-floor and fiduciary provisions, aligning with the PBM-industry witnesses' objections to the current draft.

### Testified AGAINST PBMs (for reform) · against

Ian McLaughlin

BioNJ (life sciences trade association)

A 1502

Testified in support of the Patient and Provider Protection Act, saying it addresses the 'rebate trap' where PBMs demand larger rebates for preferred formulary placement, incentivizing manufacturers to keep list prices high; urged passage with technical refinements for rare-disease drugs.

### Hearing clips

[

![Hearing clip: NJ: A 1502: Matt Greller, PCMA counsel (for)](https://app.uslege.ai/api/clip-thumbnail/bc94b95c-9cf5-4f8f-afe8-b4c586f4ea59)▶

NJ: A 1502: Matt Greller, PCMA counsel (for)

Matt Greller, solo-practitioner lobbyist testifying on behalf of PCMA (Pharmaceutical Care Management Association) · 3313-3410

“PBMs are not shadowy middlemen. They exist to lower costs on behalf of plan sponsors like unions, large and small businesses, and governments. PCMA strongly opposes this committee substitute... this bill will cost residents more while padding the profits of big pharma and pharmacists. That is not affordability. That is hypocrisy.”

Watch clip

](https://app.uslege.ai/share/bc94b95c-9cf5-4f8f-afe8-b4c586f4ea59?from=clips)[

![Hearing clip: NJ: Gov. Mikie Sherrill, Budget Address (against)](https://app.uslege.ai/api/clip-thumbnail/05d5401c-1071-4de9-ab16-1fe0b0d72d9e)▶

NJ: Gov. Mikie Sherrill, Budget Address (against)

Gov. Mikie Sherrill · 1975-2093

“Today, a type of shadowy middleman called a pharmacy benefit manager, or PBM, sits between insurers, drug makers, and pharmacies. They drive up the cost of medications as much as 10 times while padding their profits with secret manufacturer rebates and insider tricks... I look forward to partnering with you to pass a comprehensive and historic PBM reform bill.”

Watch clip

](https://app.uslege.ai/share/05d5401c-1071-4de9-ab16-1fe0b0d72d9e?from=clips)

#16 of 48

#16

## Utah

Restrictive

Utah enacted two consecutive PBM-reform statutes: HB 257 (2025), which forces rebate pass-through to enrollees and bans spread pricing when a PBM serves a self-funded plan, and HB 527 (2026), which imposes MAC-list transparency, an appeal process, and contract-disclosure duties on PBMs with Insurance Department rulemaking authority. HCR 2 (2025) is a non-binding concurrent resolution directing the state employee plan (PEHP) toward rebate pass-through. Two other bills (SB 331 non-opioid parity; SB 69/HB 519 340B manufacturer protections) are adjacent but not core PBM-business-model regulation.

Freedom from Comprehensive Reform7/25

Few PBM Mandates8/20

Light Enforcement / No Fiduciary Duty7/20

Business-Model Freedom6/20

Limited Regulatory Reach5/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

Norman Thurston

Republican · Dist. 62

HB 257

Sponsored the enacted spread-pricing ban and mandatory rebate pass-through for PBMs.

Katy Hall

Republican · Dist. 11

HB 527

Sponsored the enacted MAC-list transparency and appeal-process law for PBMs.

**Why it matters:** Utah is on an active two-year reform cadence: HB 257's spread-pricing ban and HB 527's MAC-appeal/transparency regime are both already binding, indicating the legislature will likely keep layering PBM-specific mandates in future sessions.

### Bills

HB 257Pharmacy Benefit AmendmentsRestrictive

Requires health benefit plans to use pharmaceutical rebates exclusively for enrollee benefit and compels PBMs to offer self-funded plans PBM services without spread pricing, plus insurance-commissioner support for pharmacy-association informational forms.

**Sponsor:** Norman Thurston (Republican–62)**Status:** Enacted: Governor signed, 2025**Category:** Rebate pass-through / spread-pricing ban

[View on USLege →](https://app.uslege.ai/bills/2032325)

HB 527Pharmacy Pricing AmendmentsRestrictive

Establishes stricter PBM requirements for maximum-allowable-cost (MAC) list disclosure, a pharmacy appeal process for MAC pricing, and contract transparency, with violation penalties and Insurance Department rulemaking authority.

**Sponsor:** Katy Hall (Republican–11)**Status:** Enacted: Governor signed, 2026**Category:** MAC list / contract transparency

[View on USLege →](https://app.uslege.ai/bills/3841933)

HCR 2Concurrent Resolution Directing PEHP Regarding Pharmaceutical RebatesRestrictive

Non-binding resolution directing the state employee benefit program (PEHP) to pass pharmaceutical rebate value to members at point of sale and optimize its PBM contracts accordingly.

**Sponsor:** Norman Thurston (Republican–62)**Status:** Enacted (resolution): Governor signed, 2025**Category:** Rebate pass-through (state plan)

[View on USLege →](https://app.uslege.ai/bills/2032732)

SB 331Pain Medication AmendmentsMixed-Monitor

Restricts placing non-opioid pain drugs as non-preferred when opioids are preferred and limits prior-authorization/step-therapy on non-opioids to no stricter than for opioids: a formulary-design mandate rather than a core PBM restriction.

**Sponsor:** Todd Weiler (Republican–8)**Status:** Filed, no floor vote recorded (2025)**Category:** Formulary mandate (insurer-facing)

[View on USLege →](https://app.uslege.ai/bills/2033103)

SB 69Medication Amendments (340B protection)Mixed-Monitor

Bars pharmaceutical manufacturers from restricting 340B entities' access to discounted drugs; targets manufacturer conduct, not PBM business practices directly.

**Sponsor:** Evan Vickers (Republican–28)**Status:** Enacted: became law without Governor's signature, 2025**Category:** 340B manufacturer restriction

[View on USLege →](https://app.uslege.ai/bills/2032847)

### Who testified: stakeholders on the record · 6 on the record

### Testified FOR PBMs (against new regulation) · for

Eric Cannon

Chief Commercial Officer/GM, Scribius (PBM owned by SelectHealth/Intermountain Healthcare)

HB 527

Testified with qualified opposition to HB 527's MAC-appeal/transparency mandate, objecting to the cost-shifting-to-state-employees provision and defending the PBM's existing appeal process (Senate Econ. Dev. & Workforce Services Cmte, 3/2/2026).

Jennifer Baker

Express Scripts (PBM administering PEHP's pharmacy benefit)

HB 527

Testified in opposition to HB 527, calling the MAC/appeal mandate an 'unprecedented cost-shifting mandate' onto state-employee premiums.

### Testified AGAINST PBMs (for reform) · against

Dave Davis

President, Utah Retail Merchants Association

HB 527

Testified in support of HB 527, representing community pharmacies (big-box and independent) frustrated by a near-zero PBM reimbursement-appeal approval rate.

Adam Jones

Utah Pharmacy Association

HB 527

Testified in support of HB 527's transparency/reimbursement-appeal requirements to help keep pharmacies open.

Marion First

Utah Rare Disease Advisory Council (self, rare-disease patient)

HB 527

Testified/submitted support for HB 527, citing inadequate PBM reimbursement raising costs and reducing pharmacy access for rare-disease patients.

Sheldon Birch

Owner, five independent pharmacies (Utah)

HB 527

Presented data with the bill sponsor showing pharmacies won only 10 of ~2,000 PBM reimbursement appeals, supporting HB 527's transparency/enforcement fixes.

### Hearing clips

[

![Hearing clip: UT (HB 527: Jeff Gatzmeier, Utah Pharmacy Association (against)) PBM MAC-list reimbursement pressure](https://app.uslege.ai/api/clip-thumbnail/7aa5c665-2192-4e55-a084-6abf7f9170a5)▶

UT (HB 527: Jeff Gatzmeier, Utah Pharmacy Association (against)) PBM MAC-list reimbursement pressure

Jeff Gatzmeier, President, Utah Pharmacy Association (licensed pharmacist, former pharmacy owner) · 2026-02-24 (Utah House Health and Human Services Committee), ~1:46:53–1:50:08

“Many of the large chain pharmacies are also closing locations around the country because the pressure we feel from some of these pharmacy benefit managers without any real protections on our end.”

Watch clip

](https://app.uslege.ai/share/7aa5c665-2192-4e55-a084-6abf7f9170a5?from=clips)

Only one clippable on-topic hearing found for this state; a second real clip was not available (no other on-topic hearing or opposition testimony).

#17 of 48

#17

## Virginia

Restrictive

Virginia's broad commercial-market PBM reform bill has failed repeatedly -- SB 1078 (2025) was defeated in committee 5-Y/10-N and HB 2773 (2025) died in Labor and Commerce -- but the 2026 vehicle, SB 669 (Callsen/Rouse, absorbing SB 410/SB 413), cleared committee unanimously (15-Y/0-N) and would impose a statewide spread-pricing ban, mandatory pass-through pricing, anti-retaliation protections, and an affiliated-pharmacy investigation if enacted. Meanwhile Virginia already enacted two real restrictions in 2025: SB 875/HB 2610 mandate a single, pass-through-priced, no-spread-pricing state PBM for all Medicaid pharmacy benefits, and SB 1311 expanded the statutory PBM/rebate/covered-entity definitions.

Freedom from Comprehensive Reform6/25

Few PBM Mandates8/20

Light Enforcement / No Fiduciary Duty6/20

Business-Model Freedom7/20

Limited Regulatory Reach5/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

Katrina Callsen

D

SB 669

Chief patron of the 2026 comprehensive commercial PBM bill and the enacted 2025 Medicaid single-PBM mandate (HB 2610).

Aaron Rouse

D

SB 875

Chief patron of both SB 669 (2026 comprehensive PBM bill) and the enacted SB 875 Medicaid single-PBM mandate.

Mark Peake

R

SB 1078

Sponsored comprehensive PBM reform bills in 2025 (SB 1078) and 2026 (SB 413, incorporated into SB 669).

Paul Milde

R

HB 2773

Sponsored the House companion comprehensive PBM reform bill in 2025.

Jeremy McPike

D

SB 1311

Sponsored the enacted bill expanding PBM/rebate/covered-entity definitions.

**Why it matters:** Virginia has already enacted a single-SPBM mandate with pass-through pricing for its Medicaid pharmacy benefit and now has a unanimously-advanced comprehensive commercial-market bill (SB 669) that would extend spread-pricing bans and transparency mandates statewide -- a top-tier state to watch for the 2026 session.

### Bills

SB 669Pharmacy benefits managers; requirements, application of law, report, delayed effective dateRestrictive

Enacts detailed regulatory measures for carriers and PBMs to prohibit spread pricing and undisclosed fees, mandates pass-through pricing and rebate transparency, limits retaliation against pharmacies, enforces equitable reimbursement, and requires an SCC investigation of affiliated-pharmacy inducements.

**Sponsor:** Sen. Aaron Rouse (D)**Status:** Advancing: passed committee unanimously (15-Y 0-N), absorbing SB 410/SB 413; fiscal impact statement received, 2026 session. Check USLege for current status before citing as enacted.**Category:** Comprehensive PBM regulation

[View on USLege →](https://app.uslege.ai/bills/3815861)

SB 1078Health insurance; cost-sharing, pharmacy benefits managers, compensation and duties, civil penaltyRestrictive

Would have regulated PBMs and carriers to require 80% rebate pass-through at point of sale, prohibit spread pricing and discriminatory reimbursement, and establish PBM licensing/fiduciary duties with civil penalties.

**Sponsor:** Mark Peake (R)**Status:** Failed to report (defeated) in Commerce and Labor, 5-Y 10-N, 2025 session**Category:** Comprehensive PBM regulation

[View on USLege →](https://app.uslege.ai/bills/2259662)

HB 2773Health insurance; cost-sharing, pharmacy benefits managers, compensation and duties, civil penaltyRestrictive

House companion comprehensive PBM bill requiring 80% rebate pass-through, licensing/disclosure requirements, a ban on spread pricing, and a PBM fiduciary duty enforceable via civil penalties and private action.

**Sponsor:** Paul Milde (R)**Status:** Left in Labor and Commerce (failed), 2025 session**Category:** Comprehensive PBM regulation

[View on USLege →](https://app.uslege.ai/bills/2258370)

SB 875State pharmacy benefits manager; DMAS to select & contract with a third-party administratorRestrictive

Authorizes DMAS to contract with a single state PBM for all Medicaid pharmacy benefits (including managed care), requiring transparency, pass-through pricing, and a ban on spread pricing, with a third-party consultant to implement by July 1, 2026.

**Sponsor:** Aaron Rouse (D)**Status:** Enacted -- Acts of Assembly Chapter text (CHAP0704), 2025 session**Category:** Medicaid single-PBM mandate

[View on USLege →](https://app.uslege.ai/bills/2259458)

HB 2610State pharmacy benefits manager; DMAS to select & contract with a third-party administratorRestrictive

House companion to SB 875: mandates DMAS contract with a single state PBM for all Medicaid recipients by July 1, 2026, requiring managed care organizations to use it and enforcing transparency and a spread-pricing ban.

**Sponsor:** Katrina Callsen (D)**Status:** Enacted -- Acts of Assembly Chapter text (CHAP0701), 2025 session**Category:** Medicaid single-PBM mandate

[View on USLege →](https://app.uslege.ai/bills/2258116)

SB 1311Health insurance; pharmacy benefits managers, definition of "covered entity"Restrictive

Redefines PBM-related terms including rebates and spread pricing, broadening the scope of what counts as a covered entity/PBM activity under Virginia's PBM statute (narrow but enacted expansion of PBM regulatory reach).

**Sponsor:** Jeremy McPike (D)**Status:** Enacted -- Acts of Assembly Chapter text (CHAP0429), 2025 session**Category:** PBM definitional expansion

[View on USLege →](https://app.uslege.ai/bills/2259813)

### Hearing clips

Clip captured but thumbnail failed to render server-side after extended wait; dropped to keep the report honest.

#18 of 48

#18

## Texas

Restrictive

Texas enacted two comprehensive PBM-facing laws in 2025: SB 1236 (contract transparency, fee limits, anti-recoupment, no forced network participation) and SB 493 (bars PBM gag clauses restricting pharmacist-to-patient/plan-sponsor communication). A further wave of restrictive bills stalled in committee this session: SB 1354 (NADAC/WAC reimbursement floor + appeal process), HB 5457 and HB 2750 (anti-vertical-integration / anti-forced-affiliate-PBM), and HB 3542 (continuity of coverage on PBM switch): showing sustained reform pressure even where not yet enacted.

Freedom from Comprehensive Reform6/25

Few PBM Mandates6/20

Light Enforcement / No Fiduciary Duty5/20

Business-Model Freedom6/20

Limited Regulatory Reach6/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

Bryan Hughes

Republican · Dist. 1

SB 1236

Sponsored the enacted PBM contract-transparency and fee-limit law.

Lois Kolkhorst

Republican · Dist. 18

SB 493

Sponsored the enacted anti-gag law barring PBM restrictions on pharmacist cost disclosures.

John Bryant

Democratic · Dist. 114

HB 5457

Sponsored the anti-vertical-integration bill barring PBM-pharmacy affiliations.

Cody Harris

Republican · Dist. 8

HB 2750

Sponsored the bill barring insurers from forcing enrollees into a financially-affiliated PBM.

Armando Martinez

Democratic · Dist. 39

HB 3542

Sponsored the continuity-of-coverage mandate restricting how PBM transitions affect drug coverage.

**Why it matters:** Texas has an already-binding transparency/anti-gag compliance regime (SB 1236, SB 493) plus a real near-term prospect of a reimbursement-floor and anti-affiliate-pharmacy mandate if the stalled 2025 bills are revived next session.

### Bills

SB 1236Pharmacist/pharmacy relationship with health benefit plan issuers or PBMsRestrictive

Requires online access to PBM contracts and fee schedules, bars unilateral adverse contract changes without pharmacist consent, limits fees charged before contract disclosure, and restricts recoupment and forced network-participation practices.

**Sponsor:** Bryan Hughes (Republican–1)**Status:** Enacted: effective 9/1/2025**Category:** Contract transparency & fee limits

[View on USLege →](https://app.uslege.ai/bills/808450)

SB 493Protected pharmacist/pharmacy disclosures on drug benefit costsRestrictive

Bars PBMs from restricting pharmacists from telling patients about lower out-of-pocket cash-pay costs, and voids contract clauses restricting pharmacist communication with plan sponsors about reimbursement and network access.

**Sponsor:** Lois Kolkhorst (Republican–18)**Status:** Enacted: effective 9/1/2025**Category:** Anti-gag / communication protection

[View on USLege →](https://app.uslege.ai/bills/441230)

SB 1354Minimum reimbursement for prescription drugs and devicesRestrictive

Would require PBMs to reimburse network pharmacies at least their actual acquisition cost, with a structured appeal process for reimbursement disputes and mandated PBM operational transparency.

**Sponsor:** Bryan Hughes (Republican–1)**Status:** Stalled: co-author authorized, no further floor action (2025)**Category:** Reimbursement floor / MAC appeal

[View on USLege →](https://app.uslege.ai/bills/838016)

HB 5457PBM–pharmacy affiliation and reporting requirementsRestrictive

Would prohibit affiliations between PBMs and pharmacies to prevent conflicts of interest, mandate reporting on the market impact of PBM regulation, and enforce compliance through licensing measures.

**Sponsor:** John Bryant (Democratic–114)**Status:** Stalled: referred to Insurance Committee, no further action (2025)**Category:** Anti-vertical-integration

[View on USLege →](https://app.uslege.ai/bills/999372)

HB 2750Use of a PBM in which a health plan issuer has a financial interestRestrictive

Would bar health benefit plan issuers with a financial interest in a PBM from requiring enrollees to use that affiliated PBM, targeting vertically integrated insurer-PBM steering.

**Sponsor:** Cody Harris (Republican–8)**Status:** Stalled: left pending in committee (2025)**Category:** Anti-forced-affiliate-PBM

[View on USLege →](https://app.uslege.ai/bills/810082)

HB 3542Effect of a PBM change on prescription drug coverageRestrictive

Would bar health benefit plans from denying or limiting drug coverage solely because the plan switched pharmacy benefit managers, a new mandate on plan/PBM transition practices.

**Sponsor:** Armando Martinez (Democratic–39)**Status:** Stalled: referred to Insurance Committee, no further action (2025)**Category:** Continuity-of-coverage mandate

[View on USLege →](https://app.uslege.ai/bills/895188)

HB 3265340B non-discrimination by health plans, PBMs, and manufacturersMixed-Monitor

Prohibits discriminatory reimbursement or treatment of 340B-covered entities by health plan issuers, PBMs, and manufacturers, with civil-penalty enforcement; aligns state law to federal 340B protections.

**Sponsor:** Drew Darby (Republican–72)**Status:** Advancing: committee report sent to Calendars (2025)**Category:** 340B non-discrimination

[View on USLege →](https://app.uslege.ai/bills/874245)

### Who testified: stakeholders on the record · 10 on the record

### Testified FOR PBMs (against new regulation) · for

Blake Hutson

Vice President of Public Affairs, Texas Association of Health Plans

SB 1236 / HB 2750

Testified in opposition to both SB 1236 and HB 2750, arguing against new PBM/health-plan contracting and network mandates.

Annie Spilman

Texas State Director, Texans for Affordable Healthcare (NFIB)

HB 2750

Testified in opposition to HB 2750, arguing against the anti-vertical-integration mandate on PBM/pharmacy ownership structures.

Pasha Moore

Consultant for Pharmaceutical Care Management Association (PCMA)

SB 1236 / HB 2750

Registered PCMA's formal opposition to both SB 1236 and HB 2750 (the PBM trade association itself did not verbally testify but is on the record opposed to both restrictions).

### Testified AGAINST PBMs (for reform) · against

Pete Powers

Texas Pharmacy Association

SB 1236

Testified in support of SB 1236's PBM contract-transparency and anti-recoupment mandate at the House hearing (4/1/2025).

Duane Galligher

President, Texas Pharmacy Association

SB 1236 / HB 2750

Testified in support of both SB 1236 (contract transparency) and HB 2750 (anti-vertical-integration), representing pharmacists pushing for PBM restrictions.

Charles Miller

Director of Health and Economic Mobility Policy, Texas 2036

SB 493

Testified in support of SB 493's ban on PBM gag clauses restricting pharmacist-patient communication on drug costs.

Sheila Hemphill

Founder and CEO, Texas Right To Know

SB 493

Testified in support of SB 493, framing the anti-gag-clause bill as a patient cost-transparency win against PBM practices.

John Hawkins

Texas Hospital Association

HB 2750

Testified in support of HB 2750's anti-vertical-integration / anti-forced-affiliate-PBM restrictions.

Lauren Clark

Texas Pharmacy Association

HB 2750

Testified in support of HB 2750's restrictions on PBM-affiliated pharmacy arrangements.

Kevin Rinn

Texas Federation of Drug Stores / Texas Pharmacy Association / NACDS

SB 493

Testified in support of SB 493 on behalf of the pharmacy trade coalition pushing back on PBM gag-clause practices.

### Hearing clips

No clip available. No clearly identified on-the-record advocate, for or against, is tied to any of Texas's core PBM bills (SB 1236, SB 493, SB 1354, HB 5457, HB 2750, HB 3542). The PBM-adjacent Texas video that does exist is off-topic: a Travis County Commissioners Court PBM-vendor procurement item, an unrelated Arlington City Council land-deal item, HHSC Medicaid rate-review sessions on audiology and catheter reimbursement, and a Senate HHS interim cost panel that touches SB 1236 only in passing, through unattributed panelist commentary on PBM 'middlemen'.

#19 of 48

#19

## Florida

Restrictive

Florida enacted CS/HB 697 (Ch. 2026-4), a comprehensive PBM reform bundling enhanced pharmacy appeal rights, an affiliate-reimbursement floor, an anti-clawback rule, and monthly PBM reporting; its companion bills SB1760 and SB1158 (reference pricing + additional PBM restrictions) died only because their substance passed through HB697. A wave of other 2025 restrictive bills: 340B anti-discrimination, cost-sharing accumulator bans, a Medicaid PBM-to-fee-for-service carve-out, and any-willing-pharmacist mandates: all failed, showing continued reform appetite beyond current law.

Freedom from Comprehensive Reform6/25

Few PBM Mandates7/20

Light Enforcement / No Fiduciary Duty6/20

Business-Model Freedom5/20

Limited Regulatory Reach4/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

Erin Grall

R

SB 1158

Sponsored a companion reference-pricing/PBM-restriction bill whose substance was enacted via companion CS/HB 697 (Ch. 2026-4).

Gallop Franklin

D

HB 1527

Sponsored a bill barring PBMs from interfering with 340B drug acquisition/reimbursement (failed in subcommittee).

Ana Rodriguez

R

SB 1342

Sponsored an insurer/PBM formulary-notice and cost-sharing accumulator-ban bill (failed in Banking and Insurance).

Tom Wright

R

SB 1628

Sponsored a bill moving Medicaid pharmacy benefits out of PBM-run managed care into state fee-for-service administration (failed in Health Policy).

Corey Simon

R

SB 1124

Sponsored an any-willing-pharmacist reimbursement mandate bill (failed in Banking and Insurance).

**Why it matters:** Florida has a codified comprehensive PBM reform regime (appeal rights, affiliate-reimbursement floor, anti-clawback, reporting), with several more aggressive bills (Medicaid carve-out, accumulator bans) waiting in the wings for future sessions.

### Bills

CS/HB 697Drug Prices and CoverageRestrictive

Revises the definition of pharmacy benefits plans, mandates enhanced administrative appeal rights for pharmacies disputing drug reimbursement rates, prohibits certain PBM practices, appropriates ADAP funding, mandates monthly PBM reporting, and provides for emergency rulemaking.

**Sponsor:** Health & Human Services Committee**Status:** Enacted: Chapter 2026-4 (2026-03-25)**Category:** Comprehensive PBM reform (enacted)

[View on USLege →](https://app.uslege.ai/bills/3496292)

SB 1760Health Care CoverageRestrictive

Adds an affiliated-manufacturer definition, narrows specialty-network exclusions, expands anti-clawback/appeal rules, sets a $10.24 indexed minimum dispensing fee, bars PBMs from reimbursing non-affiliate pharmacies less than affiliates, and prohibits specified PBM-manufacturer ownership ties.

**Sponsor:** Appropriations Committee**Status:** Laid on Table: substance enacted via companion CS/HB 697 (Ch. 2026-4)**Category:** Medicaid PBM reform (companion enacted)

[View on USLege →](https://app.uslege.ai/bills/3800714)

SB 1158Drug Prices and CoverageRestrictive

Creates international reference-pricing for prescription drugs, caps pharmacy/insurer reimbursement at reference prices, limits midyear formulary removals/tier increases, and adds PBM restrictions on affiliated manufacturers and pharmacy reimbursement disputes.

**Sponsor:** Erin Grall (R)**Status:** Died: substance enacted via companion CS/HB 697 (Ch. 2026-4)**Category:** Reference pricing + PBM restrictions (companion enacted)

[View on USLege →](https://app.uslege.ai/bills/3789788)

HB 1527Prohibitions Against Discriminatory Practices Relating to 340B Entities and 340B DrugsRestrictive

Would have barred drug manufacturers, insurers, PBMs, and other third parties from interfering with 340B drug acquisition, delivery, or reimbursement, deeming violations deceptive/unfair trade practices.

**Sponsor:** Gallop Franklin (D)**Status:** Died in Health Care Facilities & Systems Subcommittee (2025-06-16)**Category:** 340B/PBM anti-discrimination (failed)

[View on USLege →](https://app.uslege.ai/bills/2267925)

SB 1342Insurer Disclosures on Prescription Drug CoverageRestrictive

Would have required 60-day advance formulary-change notice, continued coverage when a physician certifies medical necessity, and mandated that PBMs/insurers apply all patient/third-party payments toward cost-sharing.

**Sponsor:** Ana Rodriguez (R)**Status:** Died in Banking and Insurance (2025-06-16)**Category:** Accumulator ban / formulary notice (failed)

[View on USLege →](https://app.uslege.ai/bills/2267744)

SB 1628Medicaid Pharmacy ServicesRestrictive

Would have moved Florida Medicaid pharmacy services out of managed-care (PBM) coverage into a state-administered fee-for-service system with a preferred drug list and direct provider reimbursement.

**Sponsor:** Tom Wright (R)**Status:** Died in Health Policy (2025-06-16)**Category:** Medicaid PBM carve-out (failed)

[View on USLege →](https://app.uslege.ai/bills/2268025)

SB 1124Pharmacist Selection and ReimbursementRestrictive

Would have let plan members select any in-network pharmacist for services within scope of practice and mandated reimbursement comparable to physicians/APRNs for the same services.

**Sponsor:** Corey Simon (R)**Status:** Died in Banking and Insurance (2025-06-16)**Category:** Any-willing-pharmacist reimbursement mandate (failed)

[View on USLege →](https://app.uslege.ai/bills/2267513)

### Who testified: stakeholders on the record · 4 on the record

### Testified FOR PBMs (against new regulation) · for

No witnesses testified in support on the record.

### Testified AGAINST PBMs (for reform) · against

Barney Bishop

Small Business Pharmacies Aligned for Reform

CS/HB 697

Testified that PBMs operate in total secrecy, steer the highest-reimbursing scripts to their own affiliated pharmacies, and are driving two neighborhood pharmacies out of business per week; urged passage.

Kelly Millet

Florida Pharmacy Association

CS/HB 697

Appeared/waived in support of the bill's PBM reimbursement and anti-loss provisions on behalf of Florida pharmacists.

McKenna Davis

US Oncology Network

CS/HB 697

Waived in support of the strike-all requiring PBMs to pay pharmacies the same rate as PBM-affiliated pharmacies and barring forced below-cost dispensing.

McKenna Davis

Epic Pharmacies

CS/HB 697

Separately waived in support of the same HB 697 strike-all on behalf of the Epic Pharmacies independent-pharmacy buying group.

### Hearing clips

No clip available. Florida's legislative video is copyrighted or restricted by state law. No on-topic PBM-reform testimony exists on the record for HB 697 or SB 1158 in any case: only floor sessions and unrelated subcommittee meetings.

#20 of 48

#20

## Kentucky

Restrictive

Kentucky's controlling standing law is **SB 50 (2020, effective July 1 2020)**, which forced Kentucky Medicaid onto a single state PBM administered on a pass-through basis, banned spread pricing in the Medicaid channel outright, mandated a single preferred drug list and dispensing-fee schedule, and imposed a $10,000 PBM licensure fee under 806 KAR 9:360: an enacted and still-binding restructuring of the PBM business model in Kentucky's largest single payer channel. Layered on top, this session enacted HB 388 (medication-synchronization mandate) and passed SB 56 through the Senate (bars PBMs/MCOs from stricter utilization controls on nonopioids than opioids), with two rebate pass-through bills (HB 512 at 85%, SB 128 at 100%) still pending in committee.

Freedom from Comprehensive Reform7/25

Few PBM Mandates6/20

Light Enforcement / No Fiduciary Duty6/20

Business-Model Freedom5/20

Limited Regulatory Reach4/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

Kimberly Moser

Republican · Dist. 64

HB 512

Sponsored the 85% rebate pass-through mandate.

Stephen Meredith

Republican · Dist. 5

SB 128

Sponsored the full (100%) rebate pass-through mandate.

Patrick Flannery

Republican · Dist. 96

HB 453

Sponsored the cash-price cost-sharing mandate binding insurers/PBMs.

Gerald Neal

Democratic · Dist. 33

SB 56

Sponsored the Medicaid PBM/MCO nonopioid utilization-parity mandate, passed by the Senate.

Robert Duvall

Republican · Dist. 17

HB 388

Sponsored the enacted medication-synchronization cost-sharing mandate.

**Why it matters:** Kentucky remains a moderate-risk state for PBM operations: current law imposes no major new burden, but two rebate-pass-through bills sitting in committee could re-emerge quickly, making the Banking & Insurance committees in both chambers the venues to watch.

### Bills

HB 512AN ACT relating to prescription drugsRestrictive

Requires at least 85% of manufacturer rebates be passed through to patients at the point of sale, with the remainder reducing plan premiums; extends to limited health service organizations and state employee health plans starting January 1, 2027.

**Sponsor:** Kimberly Moser (Republican–64)**Status:** Pending: Referred to Banking & Insurance (H), Feb 4, 2026**Category:** Rebate pass-through mandate

[View on USLege →](https://app.uslege.ai/bills/3828546)

SB 128AN ACT relating to prescription drugsRestrictive

Mandates that rebates received by insurers or PBMs be fully passed through to reduce insureds' point-of-sale costs, applying to plans issued or renewed on or after January 1, 2027, including state employee and postsecondary plans.

**Sponsor:** Stephen Meredith (Republican–5)**Status:** Pending: Referred to Committee on Committees (S), Jan 27, 2026**Category:** Rebate pass-through mandate

[View on USLege →](https://app.uslege.ai/bills/3824093)

HB 453AN ACT relating to prescription drugsRestrictive

Bars charging insured patients more in cost-sharing than the cash price of a drug and requires insurers/PBMs to count cash payments toward cost-sharing limits, effective for plans issued/renewed on or after January 1, 2027.

**Sponsor:** Patrick Flannery (Republican–96)**Status:** Pending: Referred to Banking & Insurance (H), Jan 29, 2026**Category:** Cash-price cost-sharing mandate

[View on USLege →](https://app.uslege.ai/bills/3817468)

SB 56AN ACT relating to utilization controls for nonopioid analgesics in the Medicaid programRestrictive

Bars Kentucky Medicaid MCOs and their PBMs from denying or imposing stricter utilization controls (prior authorization, step therapy) on nonopioid pain drugs than on opioids, limiting a common PBM formulary lever.

**Sponsor:** Gerald Neal (Democratic–33)**Status:** Passed Senate: retained for concurrence in House floor amendments, Apr 15, 2026**Category:** PBM/MCO utilization-management restriction

[View on USLege →](https://app.uslege.ai/bills/3797737)

HB 388AN ACT relating to prescription drugsRestrictive

Establishes prescription drug synchronization programs for chronic-illness medications and requires health insurers to provide medication synchronization with prorated cost-sharing; also updates PDMP and electronic-prescribing rules.

**Sponsor:** Robert Duvall (Republican–17)**Status:** Enacted: signed by Governor (Acts Ch. 38), Apr 7, 2026**Category:** Medication synchronization mandate

[View on USLege →](https://app.uslege.ai/bills/3805859)

### Hearing clips

No clip available for Kentucky. Kentucky legislative video is copyright-restricted, so clips cannot be generated from it. Separately, Kentucky's rebate pass-through bills (HB 512, SB 128, HB 453) remained pending in the Banking & Insurance committee with no PBM-reform hearing recorded in the 2026 session; the only adjacent Kentucky footage covers Medicaid GLP-1 rebate budget testimony rather than the bills themselves.

#21 of 48

#21

## Delaware

Restrictive

Delaware enacted HB212 (2025), shortening insurer overpayment-recovery windows and requiring written notice for PBM pharmacy recoupments, and SB271 has now passed both chambers (House 40-1) to add standardized audit/appeal procedures, prior-authorization limits, and PBM transparency reporting: a comprehensive reform package essentially at the Governor's desk. Two narrower bills cut the other way: SB182 exempts dialysate manufacturers from pharmacy licensure and HB429 preserves step-therapy tools for biosimilars, but neither offsets the incoming comprehensive audit/transparency law.

Freedom from Comprehensive Reform6/25

Few PBM Mandates7/20

Light Enforcement / No Fiduciary Duty6/20

Business-Model Freedom5/20

Limited Regulatory Reach3/15

### Favor light-touch regulation · PBM-friendly

Nicole Poore

D

HB 182

Sponsored an enacted carve-out exempting dialysate manufacturers/wholesalers from pharmacy licensure, narrowing regulatory reach.

Melissa Minor-Brown

D

HB 429

Sponsored a bill preserving/extending the step-therapy utilization-management tool to biosimilars (enacted, signed 7/23/2026).

### Favor PBM reform · reform-forward

David Sokola

D

SB 271

Sponsored comprehensive PBM audit/appeals/transparency reform (passed House 40-1, near enactment).

William Bush

D

HB 212

Sponsored the enacted law shortening overpayment-recovery windows and mandating written notice for PBM pharmacy recoupments.

Ray Seigfried

D

SJR 7

Sponsored the enacted resolution directing the state employee benefits plan to pursue independent PBM cost-containment/transparency tactics.

**Why it matters:** Delaware's PBM audit, appeals, and reporting burden is set to increase materially once SB271 is signed, compounding the 2025 recoupment-notice law: a small state moving decisively into the reform column.

### Bills

SB 271An Act to Amend Title 18 of the Delaware Code Relating to Pharmacy Benefits ManagersRestrictive

Establishes standardized pharmacy audit procedures, an appeals process for reimbursement disputes, anti-retaliation protections, limits on prior authorization for emergency/chronic prescriptions, mandatory PBM reporting to the Commissioner, and prohibitions on underpaying pharmacies and unnotified contract amendments.

**Sponsor:** David Sokola (D)**Status:** Passed By House, 40 Yes-1 Absent (2026-06-24): awaiting final enactment**Category:** Comprehensive PBM audit & transparency reform

[View on USLege →](https://app.uslege.ai/bills/3869593)

HB 212An Act to Amend Title 18 of the Delaware Code Relating to Overpayment Recovery and Audit PracticesRestrictive

Shortens the insurer overpayment-recovery window from 24 to 12 months, requires physical evidence of fraud to exceed that limit, mandates written notice for pharmacy recoupments by PBMs, and tightens the proof required to exempt an audit from pharmacy-audit protections.

**Sponsor:** William Bush (D)**Status:** Signed by Governor (2025-09-03)**Category:** Audit/recoupment restriction (enacted)

[View on USLege →](https://app.uslege.ai/bills/2311373)

SJR 7Directing the State Employee Benefits Committee to Pursue Supply-Chain Cost Containment for Prescription DrugsMixed-Monitor

Directs the State Employee Benefits Committee to engage independent consultants and pursue transparency, data ownership, and innovative negotiation tactics (e.g., reverse auctions, interstate compacts) to reduce drug costs for state employee/retiree plans.

**Sponsor:** Ray Seigfried (D)**Status:** Signed by Governor (2025-08-25)**Category:** State-plan PBM cost-containment directive (enacted)

[View on USLege →](https://app.uslege.ai/bills/2311893)

SB 182An Act to Amend Title 24 of the Delaware Code Relating to PharmacyEnabling

Exempts manufacturers and wholesalers from needing a pharmacy license to distribute dialysate drugs/devices for home dialysis, subject to FDA approval, registration, sealed packaging, and prescription/direct-delivery conditions.

**Sponsor:** Nicole Poore (D)**Status:** Signed by Governor (2025-07-21)**Category:** Licensing carve-out (deregulatory)

[View on USLege →](https://app.uslege.ai/bills/2311714)

HB 429An Act to Amend Title 18 of the Delaware Code Relating to the Step Therapy Exception ProcessEnabling

Updates the step-therapy exception process to explicitly cover biologics and biosimilars, allowing insurers/PBMs to require patients try AB-rated generics, interchangeable biologics, or biosimilars before covering the brand-name drug.

**Sponsor:** Melissa Minor-Brown (D)**Status:** Signed by the Governor, 7/23/2026 (previously passed Senate 21-0)**Category:** Step-therapy tool preserved for biosimilars

[View on USLege →](https://app.uslege.ai/bills/3881945)

### Who testified: stakeholders on the record · 1 on the record

### Testified FOR PBMs (against new regulation) · for

No witnesses testified in support on the record.

### Testified AGAINST PBMs (for reform) · against

Natalie DiSabatino

Delaware Department of Insurance

SB 271

Testified in support of SB 271's PBM audit/reimbursement-appeal reforms, saying it protects independent pharmacies and consumers even as PBM-affiliated insurance stakeholders oppose it.

### Hearing clips

[

![Hearing clip: DE (SB 271: Natalie DiSabatino, DE Dept. of Insurance (against)) PBM audit & price-gouging protections](https://app.uslege.ai/api/clip-thumbnail/b4989a47-14cc-4ad5-a128-92d44bbf2319)▶

DE (SB 271: Natalie DiSabatino, DE Dept. of Insurance (against)) PBM audit & price-gouging protections

Natalie DiSabatino, Delaware Department of Insurance · 2026-06-16 (House Economic Development/Banking/Insurance & Commerce Committee), ~43:08-44:23

“Senate bill two seventy one with senate amendment one protects consumers across the state from unnecessary data sharing and price gouging so that every Delawarean has access to affordable medicines and peace of mind.”

Watch clip

](https://app.uslege.ai/share/b4989a47-14cc-4ad5-a128-92d44bbf2319?from=clips)

Only one clippable on-topic hearing found for this state; a second real clip was not available (no other on-topic hearing or opposition testimony).

#22 of 48

#22

## Georgia

Restrictive

Georgia enacted comprehensive PBM reform via HB 946 (2020, Act 511, effective 2021, codified in Title 33 O.C.G.A.): PBM licensure through the Dept. of Insurance, a ban on retroactive DIR-fee clawbacks, MAC-list transparency plus a formal appeal process, and an anti-steering provision barring PBMs from forcing patients into affiliated/mandatory-mail-order pharmacies. That standing framework predates and is entirely separate from this session's still-pending duty-of-care bills (SB60/HB690) and rebate-transparency bills (HB100/HB101), which would layer new obligations on top of it. Georgia's score therefore reflects enacted 2020 law plus live 2025-26 reform pressure, not pending bills alone.

Freedom from Comprehensive Reform6/25

Few PBM Mandates6/20

Light Enforcement / No Fiduciary Duty5/20

Business-Model Freedom6/20

Limited Regulatory Reach4/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

Chuck Hufstetler

R

SB 60

Sponsored the Senate companion duty-of-care/PBM transparency reform bill (stalled at Senate referral).

Mark Newton

R

HB 690

Sponsored the House companion PBM duty-of-care reform bill (stalled at Second Readers).

Blake Tillery

R

SB 91

Sponsored a bill barring the state employee health plan from contracting with PBMs that own retail pharmacies (advancing: favorably reported by House committee).

Demetrius Douglas

D

HB 100

Sponsored an 80%-rebate-pass-through mandate and a companion rebate-transparency reporting bill (both stalled).

Lisa Campbell

D

HB 654

Sponsored a bill barring PBMs/insurers from conditioning payment on prior authorization (stalled at Second Readers).

**Why it matters:** Georgia retains meaningful flexibility for PBMs today, but SB91's advance and two active legislative study committees indicate the state is actively building toward PBM restrictions: a state to watch closely, not yet in the reform column.

### Bills

SB 60Pharmacy Benefits Managers; Duty of CareRestrictive

Amends Georgia's PBM regulations to impose a duty of care toward insureds, health plans, and providers; mandates transparency in operations, conflicts-of-interest disclosure, restricts affiliate-pharmacy steering, and creates a private right of action.

**Sponsor:** Chuck Hufstetler (R)**Status:** Senate Read and Referred (2025-01-30): stalled**Category:** Duty-of-care/comprehensive reform (stalled)

[View on USLege →](https://app.uslege.ai/bills/2039675)

HB 690Pharmacy Benefits Managers; Duty of CareRestrictive

House companion establishing a PBM duty of care toward insureds, health plans, and providers; mandates transparency in formulary design, pricing, and conflicts of interest, with a private right of action for violations.

**Sponsor:** Mark Newton (R)**Status:** House Second Readers (2025-03-04): stalled**Category:** Duty-of-care/comprehensive reform (stalled)

[View on USLege →](https://app.uslege.ai/bills/2038339)

SB 91State Employees' Health Insurance Plan; PBM Affiliate-Ownership Contract BanRestrictive

Prohibits the Georgia Board of Community Health from entering or renewing contracts, starting July 2026, with PBMs that own or have an ownership interest in retail pharmacies (or entities that contract with such PBMs) for the state employee health plan.

**Sponsor:** Blake Tillery (R)**Status:** House Committee Favorably Reported by Substitute (2026-03-18): advancing**Category:** Anti-affiliate-ownership (advancing, state plan only)

[View on USLege →](https://app.uslege.ai/bills/2039705)

HB 100Prescription Drug Consumer Financial Protection ActRestrictive

Would mandate that health insurers pass on at least 80% of prescription drug rebates to enrollees at the point of sale to reduce out-of-pocket costs, with compliance penalties.

**Sponsor:** Demetrius Douglas (D)**Status:** House Withdrawn, Recommitted (2025-04-04): stalled**Category:** Rebate pass-through mandate (stalled)

[View on USLege →](https://app.uslege.ai/bills/2036209)

HB 101State Employees; Annual Public Report on Prescription Drug RebatesRestrictive

Would mandate annual public reporting on prescription drug rebates and price concessions applied to premium reductions for state health plan participants, starting July 2026.

**Sponsor:** Demetrius Douglas (D)**Status:** House Withdrawn, Recommitted (2025-04-04): stalled**Category:** Rebate transparency reporting (stalled)

[View on USLege →](https://app.uslege.ai/bills/2036213)

HB 654Insurance; Prohibit Conditioning Payment on Prior AuthorizationRestrictive

Would prohibit insurers, third-party administrators, and PBMs from requiring prior authorization for covered medical tests, procedures, or prescription drugs prescribed by a licensed provider.

**Sponsor:** Lisa Campbell (D)**Status:** House Second Readers (2025-02-28): stalled**Category:** Prior-authorization restriction (stalled)

[View on USLege →](https://app.uslege.ai/bills/2038317)

SR 927Senate Pharmacy Benefits Managers and Consumer Access to Prescription Medications Study CommitteeMixed-Monitor

Creates a Senate study committee to investigate PBM practices, their impact on drug costs and independent pharmacies, and to evaluate Georgia's existing steering laws, with recommendations due December 1, 2026.

**Sponsor:** Bo Hatchett (R)**Status:** Senate Passed/Adopted (2026-03-31)**Category:** Study committee (adopted)

[View on USLege →](https://app.uslege.ai/bills/3861912)

### Who testified: stakeholders on the record · 4 on the record

### Testified FOR PBMs (against new regulation) · for

Jesse Wetherington

Georgia Association of Health Plans (President)

HB 810

Testified in respectful opposition to the reimbursement-floor mandate, requesting a later effective date and an explicit ERISA/self-funded-plan carve-out, arguing employers and insured members -- not PBMs -- would bear the cost.

Michael Power

Pharmaceutical Care Management Association (PCMA)

HB 810

Testified 'respectfully opposed' to HB 810 on behalf of PBMs, arguing the reimbursement-floor cost would be passed to plan sponsors and patients at the pharmacy counter, citing a similar Alabama law as precedent.

### Testified AGAINST PBMs (for reform) · against

Stephanie Katz

National Association of Chain Drug Stores (NACDS)

HB 810

Walked the committee through the reimbursement-floor bill, arguing PBMs claw back fees unpredictably and that the NADAC-plus-dispensing-fee floor merely lets pharmacies break even and stay open.

Nikki Bryant

Independent pharmacist/owner, Adams Family Pharmacy (Preston/Cuthbert, GA)

HB 810

Testified she survives on one store by baking goods to sell because commercial PBM reimbursement is below cost, while a transparent NADAC-plus PBM model at her other store has stabilized it; begged the committee to pass the reimbursement floor.

### Hearing clips

[

![Hearing clip: GA (HR 948: Rep. Stevens (against)) PBM transparency study committee](https://app.uslege.ai/api/clip-thumbnail/6ca6cc0e-dc53-48a4-aa29-f7dedd94b921)▶

GA (HR 948: Rep. Stevens (against)) PBM transparency study committee

Rep. Stevens (Georgia House) · 2026-02-18 (Health Committee), ~84:52-88:16

“We've seen generational pharmacies go out of business in places where there wasn't transparency with pharmacy benefit managers... we truly need to eliminate some of the smoke and mirrors.”

Watch clip

](https://app.uslege.ai/share/6ca6cc0e-dc53-48a4-aa29-f7dedd94b921?from=clips)

Only one clippable on-topic hearing found for this state; a second real clip was not available (no other on-topic hearing or opposition testimony).

#23 of 48

#23

## Maine

Restrictive

Maine's controlling standing law is **Public Law Chapter 469** (LD 1504, 'An Act To Protect Consumers from Unfair Practices Related to Pharmacy Benefits Management,' enacted 2019), which requires PBM licensure through the Bureau of Insurance AND imposes a codified FIDUCIARY DUTY on PBMs toward their carrier clients: one of the strongest state PBM fiduciary statutes in the country. (The First Circuit upheld Maine's earlier 2003 PBM-disclosure law against ERISA preemption in PCMA v. Rowe (2005); it has not ruled on this 2019 statute.) A codified fiduciary duty is the single heaviest item the enforcement factor weighs, and in Maine it is enacted statute rather than a proposal. This session's own PBM activity is narrow by comparison (two bills, SP821 and SP135) so Maine's position is set by standing law, not by pending legislation.

Freedom from Comprehensive Reform5/25

Few PBM Mandates7/20

Light Enforcement / No Fiduciary Duty4/20

Business-Model Freedom5/20

Limited Regulatory Reach5/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

Donna Bailey

Democratic · Dist. 31

SP 821

Sponsored the mail-order continuity-of-care mandate and the plan-sponsor audit-rights bill (SP 135) reaching PBM claims data.

**Why it matters:** Maine remains comparatively light-touch on PBMs; the two enacted measures are narrow, making Maine a low-priority state on the reform axis this cycle.

### Bills

SP 821An Act Regarding Mail Order Delivery of Prescription DrugsRestrictive

Requires PBMs to let patients whose mail-order prescription is delayed more than one day (or arrives unusable) fill up to a 7-day supply at a network pharmacy at no added out-of-pocket cost.

**Sponsor:** Donna Bailey (Democratic–31)**Status:** Enacted: Governor signed, Apr 13, 2026**Category:** Mail-order continuity-of-care mandate

[View on USLege →](https://app.uslege.ai/bills/3372828)

SP 135An Act to Clarify That Health Insurers Must Comply with Plan Sponsors' Statutory Rights to Audit ClaimsRestrictive

Clarifies that insurers/administrators (including PBMs) handling claims or premiums on behalf of plan sponsors must honor the sponsor's statutory right to audit claims and claims data, with timely disclosure and breach-notification duties.

**Sponsor:** Donna Bailey (Democratic–31)**Status:** Enacted: Governor signed (Emergency), Apr 13, 2026**Category:** PBM/administrator audit-rights clarification

[View on USLege →](https://app.uslege.ai/bills/2313559)

### Who testified: stakeholders on the record · 3 on the record

### Testified FOR PBMs (against new regulation) · for

Sam Hallamyre

Pharmaceutical Care Management Association (PCMA)

LD 2005 (SP 821, mail order delivery of prescription drugs)

Testified in opposition to the bill as drafted, proposing it be narrowed to in-network pharmacies and shortened to a 3-day (delay) / 7-day (unusable) bridge supply rather than a full refill.

Dan DeBarrant

Maine Association of Health Plans

LD 2005 (SP 821)

Opposed the bill as drafted, saying carriers/PBMs already offer bridge-supply accommodations and the bill lacks duration/amount limits, risking wasteful duplicate dispensing.

Christine Osinfort

Insurer/PBM industry representative (organization not stated on record)

LD 2005 (SP 821)

Opposed the bill as unnecessary, saying members can already call their PBM for an accommodation, and warned the mandate could cause wasteful duplicate prescriptions absent added limits.

### Testified AGAINST PBMs (for reform) · against

No witnesses testified in opposition on the record.

### Hearing clips

[

![Hearing clip: ME (SP 821: Sen. Donna Bailey (against)) mail-order PBM backup mandate](https://app.uslege.ai/api/clip-thumbnail/d2dc7db9-b3b2-4ce9-8a08-7c9cb8e29cd8)▶

ME (SP 821: Sen. Donna Bailey (against)) mail-order PBM backup mandate

Sen. Donna Bailey (D-31), sponsor: Joint Committee on Health Coverage, Insurance and Financial Services · 3580-3747

“My bill seeks to bolster those protections by ensuring mail order pharmacy users are guaranteed access to a backup plan should their medications arrive damaged or dangerously late.”

Watch clip

](https://app.uslege.ai/share/d2dc7db9-b3b2-4ce9-8a08-7c9cb8e29cd8?from=clips)[

![Hearing clip: ME (SP 821: Christine Osinfort (for)) opposes mail-order PBM mandate](https://app.uslege.ai/api/clip-thumbnail/afe10202-1437-4b16-83e5-7347bf4355ca)▶

ME (SP 821: Christine Osinfort (for)) opposes mail-order PBM mandate

Christine Osinfort: opponent (insurer/PBM-side) testimony, same committee hearing · 4656-4757

“We are testifying in opposition to LD 2,005 ... We are concerned that the proposal before you could lead to significant waste.”

Watch clip

](https://app.uslege.ai/share/afe10202-1437-4b16-83e5-7347bf4355ca?from=clips)

#24 of 48

#24

## Washington

Restrictive

Washington enacted the Pharmacy Benefit Manager Regulation Act (SB 5601, 2019, codified RCW 19.340): PBM registration with the Insurance Commissioner, network-adequacy standards, a ban on retroactive DIR-fee reductions, and a formal MAC-appeal process: a multi-year enacted regulatory floor that predates this session. On top of that base, 2025-26 enacted further restrictions (SB 5981, 340B access protection, effective 6/11/2026; SB 6228, ending the drug-warehousing/reselling tax exemption, effective 2027), continuing a pattern of incremental but cumulative PBM-constraining law layered year over year.

Freedom from Comprehensive Reform6/25

Few PBM Mandates6/20

Light Enforcement / No Fiduciary Duty5/20

Business-Model Freedom5/20

Limited Regulatory Reach4/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

Annette Cleveland

D

SB 5981

Sponsored the enacted 340B anti-restriction law limiting manufacturer/PBM-adjacent control of safety-net pharmacy access.

My-Linh Thai

D

HB 2145

Sponsored the House companion 340B protection bill.

Paul Harris

R

SB 5916

Sponsored both the nonopioid formulary-parity mandate and the biosimilar/utilization-management transparency bill, both restricting PBM formulary control.

Noel Frame

D

SB 6228

Sponsored the enacted tax bill removing the exemption for prescription-drug warehousing/reselling.

**Why it matters:** No single PBM Act is on the table in Washington, but the state is seeing a slow accumulation of formulary-parity and utilization-management restrictions (SB 5916, SB 5594) plus new drug-distribution taxation (SB 6228) that together narrow PBM cost-control and formulary-design tools without one bill to focus on.

### Bills

SB 5981Protecting patient access to discounted medications and health care services (340B)Restrictive

Prohibits drug manufacturers from restricting covered entities/contract pharmacies from acquiring and dispensing 340B drugs, mandates annual transparency reporting, and authorizes civil penalties for violations.

**Sponsor:** Annette Cleveland (D)**Status:** Enacted, effective 6/11/2026**Category:** 340B access protection

[View on USLege →](https://app.uslege.ai/bills/3799365)

HB 2145Protecting patient access to discounted medications and health care services (340B)Restrictive

House companion to SB 5981: bars manufacturers/distributors from restricting 340B drug acquisition or delivery to covered entities and contract pharmacies, with civil-penalty enforcement.

**Sponsor:** My-Linh Thai (D)**Status:** Referred to Rules 2 Review (pending), 2025-26 session**Category:** 340B access protection

[View on USLege →](https://app.uslege.ai/bills/3798893)

SB 5916Concerning nonopioid drugs for the treatment of painRestrictive

Bars health plans and PBM-administered formularies from disadvantaging nonopioid pain drugs versus opioids, mandating parity in formulary status and utilization-management practices effective 2027.

**Sponsor:** Paul Harris (R)**Status:** Returned to Senate Rules Committee for third reading (pending), 2025-26 session**Category:** Formulary/utilization-management parity mandate

[View on USLege →](https://app.uslege.ai/bills/3799300)

SB 6228Removing a tax exemption for the warehousing and reselling of prescription drugsRestrictive

Removes the B&O tax exemption on warehousing/reselling prescription drugs, imposing a 0.5% rate in 2027 stepping down to 0.35%, while giving critical-access pharmacies a lower rate.

**Sponsor:** Noel Frame (D)**Status:** Enacted, effective 1/1/2027**Category:** PBM/wholesaler taxation

[View on USLege →](https://app.uslege.ai/bills/3810400)

SB 5594Concerning biosimilar medicinesRestrictive

Requires transparent, timely PBM/insurer utilization-management exception processes for prescription drugs and mandates exchange-plan utilization review policies that encourage biosimilar substitution.

**Sponsor:** Paul Harris (R)**Status:** Returned to Senate Rules Committee for third reading (pending), 2025-26 session**Category:** Utilization-management transparency / biosimilar substitution

[View on USLege →](https://app.uslege.ai/bills/2415441)

### Who testified: stakeholders on the record · 7 on the record

### Testified FOR PBMs (against new regulation) · for

No witnesses testified in support on the record.

### Testified AGAINST PBMs (for reform) · against

Simona Dasgupta

Director of Pharmacy, UW Medicine

SB 5981

Testified in strong support of SB 5981's 340B contract-pharmacy protections, saying manufacturer restrictions divert safety-net revenue to profits.

Lisa Nelson

Chief Pharmacy Officer, Unity Care Northwest

SB 5981

Testified in support of SB 5981, describing 340B contract-pharmacy savings as essential to community health center services.

Victor Velasquez

Patient (self), Seattle Roots Community Health

SB 5981

Testified in support of SB 5981 as a 32-year HIV patient describing how 340B-funded care navigators and counselors depend on unrestricted contract-pharmacy access.

Marissa Ingalls

Association of Washington Healthcare Plans

SB 5594

Testified in enthusiastic support of SB 5594's biosimilar-substitution mandate on PBMs/pharmacists, calling it overdue cost-saving reform.

Chris Bandele

America's Health Insurance Plans (AHIP)

SB 5594

Testified in strong support of SB 5594, framing biosimilar substitution as the next step after past state efforts to steer PBMs/plans to lowest-cost drugs.

Brett Michelin

Association for Accessible Medicines

SB 5594

Testified in support of SB 5594 (with a proposed amendment), pushing to expand biosimilar-substitution mandates against PBM/formulary practices that suppress uptake.

Erin Jajuk

Patient Coalition of Washington

SB 5594

Testified as 'other,' supporting the reform's intent but pushing for stronger guarantees that PBM/insurer formulary placement actually lowers patient cost-sharing.

### Hearing clips

[

![Hearing clip: WA (HB 2145: Eric Ross, NewHealth FQHC (against)) 340B protections restore balance for rural patients](https://app.uslege.ai/api/clip-thumbnail/b6215aa8-3f44-4a0c-91f9-fc17f7fbea5b)▶

WA (HB 2145: Eric Ross, NewHealth FQHC (against)) 340B protections restore balance for rural patients

Eric Ross, PharmD, Chief Operations Officer, NewHealth (rural federally qualified health center) · 2026-01-20 (Washington House Health Care & Wellness Committee), ~48:34–50:00

“House Bill twenty one forty five restores balance. It protects patient access, aligns Washington with 21 other states, and ensures rural communities are not collateral damage.”

Watch clip

](https://app.uslege.ai/share/b6215aa8-3f44-4a0c-91f9-fc17f7fbea5b?from=clips)[

![Hearing clip: WA (HB 2145: Curtis Knapp, Life Science Washington (for)) bill 'moves us in the wrong direction'](https://app.uslege.ai/api/clip-thumbnail/41fd4cab-63e0-4f12-b815-619cf59846f6)▶

WA (HB 2145: Curtis Knapp, Life Science Washington (for)) bill 'moves us in the wrong direction'

Curtis Knapp, Public Affairs Manager, Life Science Washington (500+ biotech/medical device/research member trade association) · 2026-01-20 (Washington House Health Care & Wellness Committee), ~65:33–66:30

“Unfortunately, House Bill 2,145 moves us in the wrong direction.”

Watch clip

](https://app.uslege.ai/share/41fd4cab-63e0-4f12-b815-619cf59846f6?from=clips)

#25 of 48

#25

## Illinois

Most Restrictive

Illinois enacted one of the most far-reaching PBM statutes in the country this session: the Prescription Drug Affordability Act, **Public Act 104-0027** (from HB 1697), signed July 1, 2025, with group-health-plan provisions effective for policies issued, amended, or renewed on or after January 1, 2026. It bans spread pricing, bars PBMs from steering patients to pharmacies they own or control, requires 100% pass-through of rebates and fees, constrains the misclassification of common drugs as 'specialty,' guarantees plan sponsors an annual audit of rebate and fee records, and imposes a $15-per-member PBM assessment funding grants to independent pharmacies in underserved areas. Three further reform bills advanced through committee amendments in the 104th General Assembly but are held in Rules (Rule 19) and are **not law**: HB 4761 and HB 3705 (Rep. Manley (reimbursement floors, anti-spread-pricing, anti-steering, 340B protection) and HB 1018 (Rep. Cabello, R) anti-steering and transparency, a notable bipartisan reform signal). Enacted spread-pricing and steering bans plus live reimbursement-floor pressure place Illinois firmly in the restrictive tier.

Freedom from Comprehensive Reform6/25

Few PBM Mandates5/20

Light Enforcement / No Fiduciary Duty4/20

Business-Model Freedom5/20

Limited Regulatory Reach4/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

Natalie Manley

D · Dist. 98

HB 4761

Lead author of the reimbursement-floor / anti-spread-pricing PBM bill (also HB 3705).

John Cabello

R · Dist. 90

HB 1018

Republican lead author of the anti-steering/transparency PBM bill: cross-party reform risk.

**Why it matters:** Illinois shows sustained, bipartisan reform pressure (three PBM bills reached committee-amendment stage before stalling in Rules) meaning the prospect of comprehensive reimbursement-floor and anti-steering mandates persists into future sessions even though nothing has been enacted yet.

### Bills

PA 104-0027Prescription Drug Affordability Act: spread-pricing & steering banRestrictive

Bans PBM spread pricing and patient steering to PBM-owned or PBM-controlled pharmacies, requires 100% pass-through of rebates and fees, limits 'specialty drug' misclassification, guarantees plan sponsors an annual rebate-and-fee audit, and levies a $15-per-member assessment funding independent-pharmacy grants in underserved areas. Materially increases Illinois's PBM regulatory burden.

**Sponsor:** HB 1697, 104th General Assembly (signed by Gov. Pritzker**Status:** Enacted 2025) PA 104-0027 (from HB 1697), signed July 1, 2025, eff. Jan 1, 2026**Category:** Comprehensive PBM reform

[Read Public Act 104-0027 →](https://ilga.gov/documents/legislation/PublicActs/104/104-0027.htm)

HB 4761Pharmacy Benefit ReimburseRestrictive

Mandates PBM reimbursement at national average drug acquisition cost plus a fixed dispensing fee, enforces transparency/auditing/rebate-management rules, prohibits spread pricing and steering, and protects 340B-participating pharmacies.

**Sponsor:** Natalie Manley (D–98)**Status:** Re-referred to Rules Committee (Rule 19(a), March 2026): stalled**Category:** Reimbursement floor & anti-spread-pricing

[View on USLege →](https://app.uslege.ai/bills/3833635)

HB 3705Prescription Drug Affordability ActRestrictive

Regulates PBMs to enhance transparency, ensures fair reimbursement to pharmacies (including 340B and critical-access pharmacies), expands enforcement authority, mandates detailed reporting/disclosure, and prohibits certain profit practices and steering.

**Sponsor:** Natalie Manley (D–98)**Status:** House Committee Amendment No. 1 Rule 19(c): re-referred to Rules Committee, stalled**Category:** Comprehensive PBM transparency

[View on USLege →](https://app.uslege.ai/bills/2283080)

HB 1018Ins-Pharmacy Benefit ManagersRestrictive

Prohibits PBMs from steering covered individuals to pharmacies in which the PBM has ownership or control, enhances transparency and fairness in drug pricing/reimbursement, and protects 340B entities and pharmacies from discriminatory treatment.

**Sponsor:** John Cabello (R–90)**Status:** Re-referred to Rules Committee (Rule 19(a), March 2026): stalled**Category:** Anti-steering & transparency

[View on USLege →](https://app.uslege.ai/bills/2281250)

### Hearing clips

No clip available. Illinois's three PBM bills (HB 4761, HB 3705, HB 1018) reached committee-amendment stage but stalled in House Rules Committee (Rule 19) before any floor or full public hearing, so no hearing video exists to clip.

#26 of 48

#26

## Nebraska

Most Restrictive

Nebraska's PBM regime is cumulative across three sessions rather than the product of any single one. **LB767 (2022, signed, effective Jan 1 2023)** created the base Pharmacy Benefit Manager Licensure and Regulation Act (Neb. Rev. Stat. 44-4601 et seq.). LB198 (2025, signed by Gov. Pillen 49-0) then amended that Act to phase in a FULL spread-pricing ban (partial restriction from Jan 1 2026, complete prohibition Jan 1 2029), bar mandatory mail-order/affiliated-pharmacy steering and non-consensual prescription transfers, strengthen MAC-appeal rights and price-list update frequency, and give the Director of Insurance power to suspend or revoke a PBM's license and impose monetary penalties. This session's enacted LB967 additionally places PBMs under the state's unfair trade practices act. A phased spread-pricing ban, anti-steering rules, and genuine license-revocation authority together make this a comprehensive enacted reform package, placing Nebraska in the report's most restrictive tier.

Freedom from Comprehensive Reform5/25

Few PBM Mandates4/20

Light Enforcement / No Fiduciary Duty5/20

Business-Model Freedom5/20

Limited Regulatory Reach5/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

Mike Jacobson

Nonpartisan

LB 967

Sponsored the enacted omnibus that placed PBMs under the unfair trade practices act and locked in stricter licensing/penalty provisions.

Eliot Bostar

Nonpartisan

LB 1062

Sponsored the stand-alone PBM licensure-tightening bill (penalties, material-change notice) whose substance was folded into enacted LB967.

**Why it matters:** Nebraska is a low-to-moderate compliance state: enacted LB967 brings new penalty exposure and material-change notification duties, but there is no near-term prospect of spread-pricing bans, fiduciary mandates, or reimbursement floors.

### Bills

LB 967Change provisions relating to insurance fees, licensing, and trade practices, pharmacy benefit managers, mutual insurance holding companies, and related actsRestrictive

Omnibus insurance bill that includes pharmacy benefit managers under Nebraska's unfair trade practices act, and via AM2324 absorbs LB1062's PBM penalty and material-change-notification provisions, alongside broader insurance-licensing and senior-protection reforms.

**Sponsor:** Mike Jacobson (Nonpartisan)**Status:** Enacted: Approved by Governor April 7, 2026**Category:** PBM enforcement / unfair trade practices

[View on USLege →](https://app.uslege.ai/bills/3799743)

LB 1062Change provisions relating to the Insurance Producers Licensing Act and the Pharmacy Benefit Manager Licensure and Regulation ActRestrictive

Enhances Pharmacy Benefit Manager regulation by imposing administrative penalties and requiring notification of material changes, and mandates stricter PBM compliance and licensing-renewal requirements under the existing PBM Licensure and Regulation Act.

**Sponsor:** Eliot Bostar (Nonpartisan)**Status:** Indefinitely postponed as a stand-alone bill; substance folded into enacted LB967 via AM2324**Category:** PBM licensure & penalties

[View on USLege →](https://app.uslege.ai/bills/3804402)

### Who testified: stakeholders on the record · 1 on the record

### Testified FOR PBMs (against new regulation) · for

No witnesses testified in support on the record.

### Testified AGAINST PBMs (for reform) · against

Eric Dunning

Director, Nebraska Department of Insurance

LB 1062

Testified in support of LB1062's PBM provisions: streamlining the licensure late-filing penalty process for PBMs and endorsing the department's requested amendment (AM1859/adopted via LB967) to bring PBMs under the Nebraska Unfair Trade Practices Act, giving the department stronger enforcement tools over PBMs.

### Hearing clips

[

![Hearing clip: NE: LB 1062/967: Sen. Eliot Bostar (against)](https://app.uslege.ai/api/clip-thumbnail/4b839c86-05e5-459f-90d9-7e07dd5ba5aa)▶

NE: LB 1062/967: Sen. Eliot Bostar (against)

Sen. Eliot Bostar (D, sponsor of LB 1062, folded into enacted LB 967) · 262-418

“LB 1062 strengthens oversight of pharmacy benefit managers by requiring prompt notification of material changes in ownership or control and by clarifying renewal, suspension and penalty provisions. These updates ensure the Department of Insurance has accurate, timely information needed to effectively regulate PBMs.”

Watch clip

](https://app.uslege.ai/share/4b839c86-05e5-459f-90d9-7e07dd5ba5aa?from=clips)

Only one clippable on-topic hearing found for this state; a second real clip was not available (no other on-topic hearing or opposition testimony).

#27 of 48

#27

## Oregon

Most Restrictive

Oregon's 2025 session enacted three PBM-restrictive laws: HB 3226 (Ch. 303, pulls pharmacy services administrative organizations under PBM regulation), HB 2385 (Ch. 297, bars manufacturer/PBM interference with 340B drug acquisition), and HB 3409 (Ch. 346, PBM 340B claim-modifier and pricing rules). A broader fiduciary-duty bill (HB 2253), a PBM insurer-ownership ban (HB 2252), and PSAO licensure (HB 2149) all died in committee upon adjournment, so the comprehensive push stalled even as narrower 340B/PSAO protections became law.

Freedom from Comprehensive Reform4/25

Few PBM Mandates6/20

Light Enforcement / No Fiduciary Duty5/20

Business-Model Freedom5/20

Limited Regulatory Reach4/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

Rob Nosse

D · Dist. 42

HB 2385 / HB 2149

Sponsored the enacted 340B anti-interference law and the stalled PSAO licensure bill.

Kim Wallan

R · Dist. 6

HB 2253 / HB 2252

Sponsored both the PBM fiduciary-duty bill and the PBM insurer-ownership ban.

**Why it matters:** Oregon keeps chipping away at PBM practices piecemeal (340B, PSAOs) rather than passing one big bill; the fiduciary-duty and PBM-ownership bills that would matter most to the business model failed in 2025 but will likely return.

### Bills

HB 3226PSAOs treated as pharmacies under PBM lawRestrictive

Expands the definition of 'pharmacy' to include pharmacy services administrative organizations so PBM contracts routed through them are still subject to PBM regulation.

**Sponsor:** Rob Nosse (D–42)**Status:** Enacted (Ch. 303, 2025 Laws)**Category:** PSAO regulation

[View on USLege →](https://app.uslege.ai/bills/2216222)

HB 2385340B anti-interference protectionsRestrictive

Bars manufacturers and PBMs from restricting 340B drug acquisition, delivery, or dispensing through contract pharmacies; civil penalties enforced by the Board of Pharmacy.

**Sponsor:** Rob Nosse (D–42)**Status:** Enacted (Ch. 297, 2025 Laws)**Category:** 340B protections

[View on USLege →](https://app.uslege.ai/bills/2216679)

HB 3409340B claim-modifier and PBM pricing rulesRestrictive

Regulates PBM claim-modifier requirements for 340B drugs, bans discriminatory 340B pharmacy treatment, and mandates a data clearinghouse for claim validation.

**Sponsor:** Ben Bowman (D) (carried by Rep. Rob Nosse, D)**Status:** Enacted (Ch. 346, eff. Sept. 2025)**Category:** 340B / MAC transparency

[View on USLege →](https://app.uslege.ai/bills/2217629)

HB 2253PBM fiduciary duty to enrolleesRestrictive

Would require PBMs to act as fiduciaries when negotiating drug prices and create a DCBS complaint process for breaches; did not pass.

**Sponsor:** Kim Wallan (R–6)**Status:** Stalled (in committee upon adjournment, 2025)**Category:** Fiduciary duty

[View on USLege →](https://app.uslege.ai/bills/2216492)

HB 2252PBM insurer-ownership banRestrictive

Would bar a person from registering as a PBM in Oregon unless it proves it is not owned or operated by an insurer or insurer affiliate; failed to advance.

**Sponsor:** Kim Wallan (R–6)**Status:** Stalled (in committee upon adjournment, 2025)**Category:** Structural separation

[View on USLege →](https://app.uslege.ai/bills/2216502)

HB 2149PSAO licensureRestrictive

Would require pharmacy services administrative organizations to be licensed by DCBS with disclosure and revocation rules; did not pass.

**Sponsor:** Rob Nosse (D–42)**Status:** Stalled (in committee upon adjournment, 2025)**Category:** PSAO licensing

[View on USLege →](https://app.uslege.ai/bills/2216392)

### Hearing clips

No usable clip for Oregon. The available Oregon footage on this topic covers Prescription Drug Affordability Board meetings and a general DCBS insurance-regulator overview: PBM-adjacent, but not testimony on Oregon's enacted PBM bills (HB 3226, HB 2385, HB 2253). No committee or floor hearing carrying clear for/against testimony on those bills was recorded.

#28 of 48

#28

## Iowa

Most Restrictive

Iowa's SF 383 (from SSB 1074, Senate HHS Committee) reached final passage in 2025: a comprehensive PBM law requiring pass-through pricing, fairness/non-discrimination in pharmacy reimbursement and participation, and reporting/oversight of PBM and pharmacy-services-administrative-organization practices, effective July 1, 2025. A parallel Commerce Committee bill (SSB 1207) pushing an explicit spread-pricing ban, mandatory rebate pass-through, and dispensing-fee floors for 'pharmacy deserts' advanced through subcommittee before being effectively subsumed/stalled.

Freedom from Comprehensive Reform5/25

Few PBM Mandates6/20

Light Enforcement / No Fiduciary Duty5/20

Business-Model Freedom3/20

Limited Regulatory Reach3/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

No sponsor-derived skeptics.

**Why it matters:** Iowa has already locked in a comprehensive pass-through/fairness PBM statute, and a second, more aggressive spread-pricing-ban bill remains live in Commerce: pointing to continued incremental tightening rather than a stable baseline.

### Bills

SF 383Pharmacy benefits managers, pharmacies, prescription drugs, and pharmacy services administrative organizationsRestrictive

Regulates PBMs, pharmacies, and pharmacy-services-administrative-organizations to ensure transparency, fairness in pricing and reimbursement, and protection of pharmacy/patient rights, with mandated reporting and oversight of distribution practices beginning July 1, 2025.

**Sponsor:** Senate Health and Human Services Committee**Status:** Passed; effective July 1, 2025**Category:** Comprehensive PBM reform

[View on USLege →](https://app.uslege.ai/bills/2265585)

SSB 1207Pharmacy benefits managers, pharmacies, and prescription drugsRestrictive

Prohibits PBM spread pricing, mandates full rebate pass-through to reduce premiums, bars mandatory exclusive mail-order pharmacy use (except specialty drugs), and mandates professional dispensing fees for pharmacies, particularly in designated 'pharmacy deserts.'

**Sponsor:** Senate Commerce Committee**Status:** Subcommittee recommended amendment and passage (March 2025); no further recorded action: stalled**Category:** Spread-pricing ban & dispensing-fee floor

[View on USLege →](https://app.uslege.ai/bills/2265152)

### Hearing clips

[

![Hearing clip: IA (SF 383: Rep. Meyer (against)) cites enacted PBM reform, calls PBMs 'a significant problem'](https://app.uslege.ai/api/clip-thumbnail/33c99526-76d8-48a3-8ec2-7aa51e8df114)▶

IA (SF 383: Rep. Meyer (against)) cites enacted PBM reform, calls PBMs 'a significant problem'

Rep. Meyer (Webster), HHS budget floor manager · 11:10-12:40

“This legislature, last year, passed significant PBM reform that has held up in the courts. I continue to believe that PBMs are a significant problem and that more transparency will lead to lower pharmaceutical costs.”

Watch clip

](https://app.uslege.ai/share/33c99526-76d8-48a3-8ec2-7aa51e8df114?from=clips)

Only one clippable on-topic hearing found for this state; a second real clip was not available (no other on-topic hearing or opposition testimony).

#29 of 48

#29

## Maryland

Most Restrictive

Maryland's regulatory baseline is already among the toughest in the country: its 2019 Prescription Drug Affordability Board Act (Ch. 692, HB 768/SB 759) gave the state's PDAB authority to set upper payment limits on drugs, predating USLege's bill-data window but still the load-bearing law. On top of that, HB 813 (2025, enacted, Ch. 730) convened a PBM study workgroup on Medicaid-MCO pharmacy reimbursement (the NADAC-plus-dispensing-fee floor was in the companion SB 438, which stalled); a companion (SB 438) and a mixed purchaser-definition bill (SB 303/HB 321, narrows PBM oversight for certain nonprofit HMOs but adds new audit/reimbursement/appeal rules) stalled after hearings. Two 2026 bills are pending: SB 837 would bar insurers/PBMs from prior-authorization or step-therapy limits on PDAB-reviewed drugs, and HB 1114 would eliminate PBM prior-authorization and cost-sharing for HIV PrEP under Medicaid.

Freedom from Comprehensive Reform4/25

Few PBM Mandates6/20

Light Enforcement / No Fiduciary Duty5/20

Business-Model Freedom4/20

Limited Regulatory Reach3/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

Steve Johnson

Democratic · Dist. 34

HB 813

Sponsored the enacted Medicaid PBM reimbursement-floor and study-workgroup law.

Clarence Lam

Democratic · Dist. 12

SB 438

Sponsored the stalled PBM reimbursement-floor companion bill (SB 438) and the mixed purchaser-definition bill (SB 303).

Justin Ready

Republican · Dist. 5

SB 837

Sponsored the pending bill stripping PBM prior-authorization/step-therapy tools for PDAB-reviewed drugs.

Ashanti Martinez

Democratic · Dist. 22

HB 1114

Sponsored the pending bill eliminating PBM prior-authorization and cost-sharing for HIV PrEP.

**Why it matters:** Maryland combines a hard comprehensive drug-affordability law with an active pipeline of bills further stripping PBM utilization-management tools, pointing to continued erosion of PBM formulary control here.

### Bills

HB 768 / SB 759 (2019)Prescription Drug Affordability Board ActRestrictive

Established Maryland's Prescription Drug Affordability Board, one of the first in the nation, with authority to review drug costs and set upper payment limits: a load-bearing comprehensive law still in force. Cited to its session law rather than the platform's bill feed because it predates that feed's coverage; see the Maryland General Assembly's official chapter record.

**Sponsor:** Not carried in the platform's bill-data window**Status:** Enacted 2019 (Ch. 692): predates USLege bill-data window**Category:** Comprehensive drug affordability board / upper payment limits

[View on USLege →](https://mgaleg.maryland.gov/mgawebsite/Legislation/Details/sb1023?ys=2019RS)

HB 813Maryland Insurance Administration and Maryland Department of Health - Workgroup to Study Pharmacy Benefits ManagersRestrictive

Sets a workgroup to study pharmacist reimbursement (NADAC plus professional dispensing fee) for PBMs contracting on behalf of Medicaid managed care organizations, and convenes a stakeholder workgroup to study PBM operations, reimbursement, and specialty-drug coverage.

**Sponsor:** Steve Johnson (Democratic–34)**Status:** Enacted: Approved by Governor, Chapter 730, May 20, 2025**Category:** PBM reimbursement floor + study workgroup

[View on USLege →](https://app.uslege.ai/bills/2293221)

SB 438Pharmacy Benefits Administration - Maryland Medical Assistance Program and Pharmacy Benefits ManagersRestrictive

Would mandate NADAC-plus-dispensing-fee minimum reimbursement for pharmacies under Medicaid and expand the 'purchaser' definition to include insurers and health plans, applying the mandate to PBMs acting for managed care organizations.

**Sponsor:** Clarence Lam (Democratic–12)**Status:** Stalled: hearing held 2/12/2025, no further action**Category:** PBM reimbursement floor (companion to HB 813)

[View on USLege →](https://app.uslege.ai/bills/2295640)

SB 303Pharmacy Benefits Managers - Definition of Purchaser and Alteration of Application of LawMixed-Monitor

Narrows the PBM 'purchaser' definition to exclude certain nonprofit HMOs from oversight, but simultaneously adds new PBM audit standards, reimbursement protocols, and internal-appeals requirements: net effect is additional PBM regulation with a narrow carve-out.

**Sponsor:** Clarence Lam (Democratic–12)**Status:** Stalled: hearing held 2/05/2025, no further action**Category:** Mixed purchaser-definition / audit reform

[View on USLege →](https://app.uslege.ai/bills/2295497)

SB 837Maryland Medical Assistance Program and Health Insurance - Coverage and Utilization Review - Drugs Reviewed by the Prescription Drug Affordability BoardRestrictive

Would bar MCOs and insurers from requiring prior authorization or step therapy, or limiting coverage, for drugs the PDAB has reviewed without finding affordability problems: removing a standard PBM utilization-management lever.

**Sponsor:** Justin Ready (Republican–5)**Status:** Pending: hearing scheduled 3/04/2026**Category:** PBM prior-authorization restriction

[View on USLege →](https://app.uslege.ai/bills/3843982)

HB 1114HIV Prevention Drugs - Prescribing, Dispensing, and Insurance CoverageRestrictive

Requires Maryland Medicaid to cover FDA-approved HIV PrEP drugs and eliminates prior authorization and cost-sharing for HIV prevention drugs and related services, removing PBM utilization-management tools for this drug class.

**Sponsor:** Ashanti Martinez (Democratic–22)**Status:** Pending: hearing scheduled 3/04/2026**Category:** PBM prior-authorization / cost-sharing elimination

[View on USLege →](https://app.uslege.ai/bills/3845152)

### Who testified: stakeholders on the record · 4 on the record

### Testified FOR PBMs (against new regulation) · for

Ray Baker

Baltimore-DC Building Trades Council

SB 303

Testified unfavorably, citing concern the bill could raise dispensing fees, alter mail-order terms for retiree plans, and change existing pharmacy networks his union members rely on.

Victoria Leonard

Laborers' Local 11 (LIUNA)

SB 303

Testified unfavorably, arguing the bill would create inconsistent multi-state rules for her union's cross-jurisdiction (MD/VA/DC) health plan, raising co-pays and cutting member benefits.

### Testified AGAINST PBMs (for reform) · against

Kaylee Locklear

Maryland Association of Chain Drug Stores

SB 303

Testified in support of extending Maryland's PBM/pharmacy protections to ERISA self-funded plans, citing FTC findings on PBM markups and mass pharmacy closures.

Michael Patti

Independent Pharmacies of Maryland

SB 303

Supported SB303, arguing PBM premium regulation by MIA has not caused the rate spikes industry warns of and citing similar laws in Florida and New York.

### Hearing clips

[

![Hearing clip: MD (HB 1469: bill sponsor (against)) PBM specialty-drug steering](https://app.uslege.ai/api/clip-thumbnail/f5cc53dc-1baa-4fac-8f4c-5e4179bd8b67)▶

MD (HB 1469: bill sponsor (against)) PBM specialty-drug steering

Marwa Mamandy (legislative aide presenting on behalf of the sponsor) · 1123-1293

“PBMs utilize the current definition of specialty drug to dispense them through affiliate and specialty pharmacies steering patients away from local retail pharmacies. This increases profits for PBMs which in turn drives costs in commercial and Medicaid markets.”

Watch clip

](https://app.uslege.ai/share/f5cc53dc-1baa-4fac-8f4c-5e4179bd8b67?from=clips)

Only one clippable on-topic hearing found for this state; a second real clip was not available (no other on-topic hearing or opposition testimony).

#30 of 48

#30

## Ohio

Most Restrictive

Ohio has enacted two structural PBM restrictions predating this session: (1) PBM registration/licensure requirements administered by the State Board of Pharmacy (Ohio Rev. Code Ch. 3959, enacted circa 2018-2020) with gag-clause and MAC-appeal protections; and (2) most significantly, after a 2018 state audit found PBMs spread-priced Ohio Medicaid managed care by over $224 million in a single year, Ohio Medicaid eliminated commercial PBM spread-pricing entirely by moving to a single state-procured PBM (Gainwell, live since October 2022) for all Medicaid managed-care pharmacy claims: the most direct structural elimination of PBM spread-pricing revenue of any state in this report.

Freedom from Comprehensive Reform5/25

Few PBM Mandates5/20

Light Enforcement / No Fiduciary Duty4/20

Business-Model Freedom4/20

Limited Regulatory Reach4/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

Louis Blessing

R · Dist. 8

SB 210

Sponsors the comprehensive PBM licensing/fiduciary-duty bill, the most far-reaching pending measure.

Tim Barhorst

R · Dist. 85

HB 192

Sponsors PBM drug-cost reporting mandate and accreditation limits.

Kellie Deeter

R · Dist. 54

HB 972

Sponsors anti-steering bill barring PBMs from restricting pharmacy transparency services.

Derrick Hall

D · Dist. 34

HB 890

Sponsors the PRICE Act creating a drug affordability board with upper payment limits.

Susan Manchester

R · Dist. 12

SB 207

Sponsors copay-accumulator ban restricting PBM/insurer cost-sharing design.

Rachel Baker

D · Dist. 27

HB 448

Sponsors rebate pass-through mandate forcing PBM rebates to point-of-sale.

**Why it matters:** Ohio is a high-priority watch state, without a comprehensive law yet enacted: SB 210's comprehensive licensing/fiduciary framework and HB 890's price-cap board are the two bills to watch before they reach a floor vote.

### Bills

SB 210PBM Licensing and ContractsRestrictive

Establishes a comprehensive PBM licensing and regulatory framework effective 2027 with mandated contractual/financial disclosures, fiduciary duties, transparent bookkeeping, and superintendent-of-insurance oversight.

**Sponsor:** Louis Blessing (R–8)**Status:** Refer to Committee (pending), 136th General Assembly**Category:** Comprehensive PBM licensure/fiduciary duty

[View on USLege →](https://app.uslege.ai/bills/2074842)

HB 192Community Pharmacy Protection ActRestrictive

Limits insurer/PBM pharmacy-accreditation requirements to state Board of Pharmacy standards and mandates quarterly detailed electronic drug-cost reports from PBMs with penalties for violations.

**Sponsor:** Tim Barhorst (R–85)**Status:** Refer to Committee (pending), 136th General Assembly**Category:** Reporting mandate / accreditation limit

[View on USLege →](https://app.uslege.ai/bills/2074177)

HB 972Prohibit Certain Health Plan Issuer Pharmacy RestrictionsRestrictive

Bars health plan issuers/PBMs from restricting pharmacies or prescribers from offering patients cost-transparency tools, adherence support, copay assistance, and other pharmacy-choice services.

**Sponsor:** Kellie Deeter (R–54)**Status:** Introduced (pending), 136th General Assembly**Category:** Anti-steering

[View on USLege →](https://app.uslege.ai/bills/3888317)

HB 890Prescription Relief, Inflation Cost Elimination (PRICE) ActRestrictive

Creates a Prescription Drug Affordability Board empowered to conduct affordability reviews and set upper payment limits on high-cost or rapidly-increasing drugs, with ongoing reporting to the General Assembly.

**Sponsor:** Derrick Hall (D–34)**Status:** Refer to Committee (pending), 136th General Assembly**Category:** Drug affordability board / price caps

[View on USLege →](https://app.uslege.ai/bills/3880477)

SB 207Prohibit Certain Health Insurance Cost-Sharing PracticesRestrictive

Limits copayments/deductibles to reasonable federally-aligned amounts, bars insurers/PBMs from altering coverage based on copay-assistance availability, and mandates annual certifications to the superintendent of insurance.

**Sponsor:** Susan Manchester (R–12)**Status:** Refer to Committee (pending), 136th General Assembly**Category:** Accumulator ban / cost-sharing cap

[View on USLege →](https://app.uslege.ai/bills/2074821)

HB 448Apply Prescription Drug Rebates to Cost-Sharing RequirementsRestrictive

Mandates health plan issuers apply all PBM-negotiated rebates and price concessions at the point of sale to reduce a covered person's cost-sharing, with confidentiality protections for rebate details.

**Sponsor:** Rachel Baker (D–27)**Status:** Refer to Committee (pending), 136th General Assembly**Category:** Rebate pass-through mandate

[View on USLege →](https://app.uslege.ai/bills/2195683)

### Who testified: stakeholders on the record · 1 on the record

### Testified FOR PBMs (against new regulation) · for

No witnesses testified in support on the record.

### Testified AGAINST PBMs (for reform) · against

David Burke

Executive Director, Ohio Pharmacists Association (former state senator)

SB 210

Told the Senate Finance Committee that SB 210's PBM transparency framework is needed to stabilize the collapsing Ohio pharmacy market, urged reinstating a NADAC-plus-dispensing-fee payment floor for pharmacies, and credited the state's single-PBM Medicaid move with $140M in savings over two years.

### Hearing clips

No clip available. Ohio's legislative video is copyrighted or restricted by state law, so no clip can be created from it.

#31 of 48

#31

## Hawaii

Most Restrictive

Hawaii enacted HB 1643 (Act 039, 2026) locking in a comprehensive pharmacy-audit framework that narrows PBM audit authority, while SB 2047 (MAC-list transparency, appeals process, DCCA enforcement/fines: passed Senate, amended in House Finance as of March 2026) and HB 2225 (a full Reform Act: nondiscrimination, NADAC+dispensing-fee reimbursement floor, mandatory pass-through/spread-pricing ban effective 2027) are both actively advancing. A Senate-adopted PBM Working Group resolution (SR 53) adds further reform momentum.

Freedom from Comprehensive Reform4/25

Few PBM Mandates5/20

Light Enforcement / No Fiduciary Duty4/20

Business-Model Freedom3/20

Limited Regulatory Reach4/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

Jarrett Keohokalole

D · Dist. 24

SB 2047

Lead author of MAC-transparency/enforcement bill against PBM audit and pricing practices.

Tina Grandinetti

D · Dist. 20

HB 2225

Lead author of the comprehensive PBM reimbursement-floor and spread-pricing-ban Reform Act.

Scot Matayoshi

D · Dist. 49

HB 1643

Lead author of the enacted pharmacy-audit restriction law narrowing PBM audit authority.

**Why it matters:** Hawaii is an active-reform state: an enacted audit-restriction law is already in force and two broader reimbursement-floor/transparency bills are moving through committee with bipartisan-adjacent support, meaning near-term compliance costs for PBMs and a real chance of a full reform package landing within a cycle or two.

### Bills

SB 2047Insurance Commissioner; Pharmacy Benefit Managers; Prescription Drugs; Maximum Allowable Cost; Contracting Pharmacies; AppropriationRestrictive

Reestablishes statutory regulation of PBM maximum-allowable-cost (MAC) lists, mandating transparency, a structured appeals process for MAC pricing disputes, and disclosure of lower-priced equivalents, with DCCA oversight and enforcement including fines and corrective actions.

**Sponsor:** Jarrett Keohokalole (D–24)**Status:** Passed Senate as amended; referred to House Finance as amended in HD 2 (March 2026)**Category:** MAC transparency & enforcement

[View on USLege →](https://app.uslege.ai/bills/3819438)

HB 2225Pharmacy Benefit Managers; Prescription Drug Benefit Plans; Providers; Beneficiaries; Cost Sharing; Pass-Through Pricing; Spread PricingRestrictive

Establishes PBM nondiscrimination requirements, mandates that beneficiary cost-sharing reflect point-of-sale rebates, sets a minimum reimbursement floor (national acquisition cost plus dispensing fee), and requires pass-through pricing or spread-savings pass-through in PBM contracts executed after July 1, 2027.

**Sponsor:** Tina Grandinetti (D–20)**Status:** Referred to House Health & Consumer Protection & Commerce committees (Jan 2026)**Category:** Comprehensive PBM reform

[View on USLege →](https://app.uslege.ai/bills/3823215)

HB 1643Pharmacy; Registered Pharmacists; Audits; Pharmacy Benefit Managers; Exclusion; Health Maintenance OrganizationRestrictive

Establishes a comprehensive framework regulating PBM/pharmacy audits: written-notice requirements, limited audit scope and methods, recoupment/appeals processes, and a narrow exclusion of certain HMOs from the PBM definition.

**Sponsor:** Scot Matayoshi (D–49)**Status:** Enacted: Act 039 (05/26/2026)**Category:** Pharmacy audit restrictions

[View on USLege →](https://app.uslege.ai/bills/3819225)

SR 53Pharmacy Benefit Manager (PBM) Working GroupMixed-Monitor

Requests the state health planning agency convene a PBM Working Group to evaluate and recommend PBM reforms (transparency, reimbursement, reporting), reporting back to the legislature by 2026: non-binding but signals continued reform pressure.

**Sponsor:** Glenn Wakai (D–15)**Status:** Adopted (Senate Resolution, 2026)**Category:** Study / working group

[View on USLege →](https://app.uslege.ai/bills/3283405)

### Who testified: stakeholders on the record · 11 on the record

### Testified FOR PBMs (against new regulation) · for

Tanya Neal

Pharmaceutical Care Management Association (PCMA)

SB2047

PCMA (the national PBM trade group) pushed amendments to narrow the bill's expanded reimbursement/operational provisions back toward the pre-repeal, PBM-friendlier scope.

Moani Wisk (HMSA rep, "Walden")

HMSA

HB1643

Raised concerns that limiting PBM/insurer audit scope and overpayment-recoupment authority could undermine program-integrity efforts against fraud and abuse.

Tonya Neal

Pharmaceutical Care Management Association (PCMA)

HB1643

PCMA (the PBM industry's own national trade group) proposed amendments to soften the pharmacy-audit restriction provisions, per Hawaii Pharmacists Association's testimony referencing PCMA's proposed changes.

### Testified AGAINST PBMs (for reform) · against

Jack Lewin

State Health Planning & Development Agency (SHPDA / "Shipta")

SB2047

Testified in support of the MAC-transparency/reimbursement-safeguard bill, saying it would help stabilize independent contracting pharmacies against PBM pricing practices.

Corey Sanders

Hawaii Pharmacists Association

SB2047

Opposed the amendment that would narrow pricing-transparency protection to PBM-network pharmacies only; supported the bill's core MAC-transparency framework.

McHenry Woodward

Office of Hawaiian Affairs

SB2047

Testified in support of the PBM MAC-transparency/reimbursement bill on behalf of OHA.

Christopher Fernandez

DCCA Board of Pharmacy (Executive Officer)

HB1643

Board stood on testimony supporting the intent of the pharmacy-audit restriction bill, while flagging that the existing volume of PBM audits already burdens pharmacist workload/patient care.

Corey Sanders

Hawaii Pharmacists Association

HB1643

Testified in strong support of the pharmacy-audit restriction bill, calling current PBM audit practices on independent pharmacies excessive and time-sensitive to fix before slower federal PBM reforms arrive.

Kimberly Mikami Sveten

President, Molokai Drugs Inc.

HB1643

Rural pharmacist testified her pharmacy is audited almost weekly by PBMs/insurers (including flown-in mainland auditors), urging passage of the fair-audit framework.

Kelly Go

Pharmacist in Charge, Molokai Drugs Inc.

HB1643

Testified in support of the pharmacy audit-fairness bill at the Senate HHS hearing.

John Kiri(mitsu)

Kaiser Permanente

HB1643

Testified "in support" of the audit-restriction bill while requesting a technical amendment.

### Hearing clips

[

![Hearing clip: HI (HB 1643: Tonya Neal, PCMA (for)) national PBM trade association testifies](https://app.uslege.ai/api/clip-thumbnail/70b0ce05-dc72-4b54-b5b4-39b1ba7cb871)▶

HI (HB 1643: Tonya Neal, PCMA (for)) national PBM trade association testifies

Tonya Neal, Senior Director of State Affairs, Pharmaceutical Care Management Association (PCMA) · 21:57-22:56

“I am the senior director for state affairs for the Pharmaceutical Care Management Trade Association. We are the National Trade Association for Pharmacy Benefit Managers.”

Watch clip

](https://app.uslege.ai/share/70b0ce05-dc72-4b54-b5b4-39b1ba7cb871?from=clips)[

![Hearing clip: HI (HB 1643: Corey Sanders, Hawaii Pharmacists Assoc. (against)) pushes back on PCMA audit amendments](https://app.uslege.ai/api/clip-thumbnail/9bb51e4e-819f-4ea4-a530-cc0b41e3f338)▶

HI (HB 1643: Corey Sanders, Hawaii Pharmacists Assoc. (against)) pushes back on PCMA audit amendments

Corey Sanders, Executive Director, Hawaii Pharmacists Association · 20:20-21:50

“Our island pharmacies are small, they're very small staffed... we're asking that the auditors aren't allowed into the prescription area.”

Watch clip

](https://app.uslege.ai/share/9bb51e4e-819f-4ea4-a530-cc0b41e3f338?from=clips)

#32 of 48

#32

## Minnesota

Most Restrictive

Minnesota already has an ENACTED comprehensive PBM regime (Minn. Stat. Ch. 62W (PBM Licensure and Regulation Act, effective 2020)) imposing licensure, fiduciary duty, and conduct restrictions on PBMs. The 2025-26 sessions are actively layering MORE restriction on top: SF 3063 / HF 2851 add a spread-pricing ban, higher license fees, and MAC-appeal rules; HF 2242 goes further and would replace private PBMs with a single state-procured PBM for Medicaid/MinnesotaCare managed care.

Freedom from Comprehensive Reform2/25

Few PBM Mandates3/20

Light Enforcement / No Fiduciary Duty3/20

Business-Model Freedom5/20

Limited Regulatory Reach5/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

Alice Mann

D · Dist. Senate 50

SF 3063

Prime sponsor of the spread-pricing ban and fiduciary-duty expansion to MN's existing PBM licensure act.

Steve Elkins

D · Dist. House 50

HF 2851

House companion sponsor of the spread-pricing ban and fiduciary-duty bill.

Danny Nadeau

R · Dist. House

HF 2242

Republican sponsor of a bill to replace commercial PBMs with a single state-procured PBM for Medicaid managed care.

**Why it matters:** MN is a heavily-regulated state for PBMs and getting more restrictive, not less: the open question is how much further the existing 62W framework gets tightened, including a live proposal (HF 2242) to functionally replace commercial PBMs with a state PBM for public programs.

### Bills

Minn. Stat. Ch. 62WPharmacy Benefit Manager Licensure and Regulation ActRestrictive

Requires PBM licensure by the MN Commerce Department, imposes fiduciary duties, and restricts certain PBM business practices; the enacted baseline framework the 2025-26 bills below amend and expand. Cited per official state source, not USLege session data.

**Sponsor:** Minnesota Legislature (codified law)**Status:** Enacted 2019 (effective 2020), predates USLege data window**Category:** Comprehensive PBM licensure

[View on USLege →](https://www.revisor.mn.gov/statutes/cite/62W)

SF 3063PBM spread pricing prohibition and fiduciary duty modificationsRestrictive

Prohibits PBM spread pricing, raises license application/renewal fees, imposes fiduciary duties, enhances transparency/reporting, and sets detailed MAC pricing and appeal rules: tightening the existing 62W framework.

**Sponsor:** Alice Mann (D–Senate 50)**Status:** Referred to Commerce and Consumer Protection (2025-03-27)**Category:** Spread pricing / fiduciary duty

[View on USLege →](https://app.uslege.ai/bills/3248189)

HF 2851PBM spread pricing prohibition (House companion)Restrictive

House companion to SF 3063: bans PBM spread pricing, imposes fiduciary duties, raises licensing fees, and strengthens fair-reimbursement and reporting requirements with added enforcement appropriations.

**Sponsor:** Steve Elkins (D–House 50)**Status:** Referred to Health Finance and Policy (2025-03-26)**Category:** Spread pricing / fiduciary duty

[View on USLege →](https://app.uslege.ai/bills/3244848)

HF 2242State pharmacy benefit manager required for Medicaid managed careRestrictive

Requires the state to competitively procure a single PBM for Medical Assistance/MinnesotaCare managed care, with the commissioner overseeing pricing transparency and utilization management: a structural move against the commercial multi-PBM model, with bipartisan authorship.

**Sponsor:** Danny Nadeau (R–House (district not confirmed))**Status:** Referred to Health Finance and Policy; author added 2025-04-03**Category:** State PBM / market structure

[View on USLege →](https://app.uslege.ai/bills/3245467)

SF 3055PBM technology platform and data protection in state vendor contractsRestrictive

Introduces a reverse-auction bidding process for state PBM contracts and requires an independent technology platform for claims adjudication, with data-security mandates: reduces PBM discretion in state procurement.

**Sponsor:** Alice Mann (D–Senate 50)**Status:** Referred to State and Local Government (2025-03-27)**Category:** Procurement / data oversight

[View on USLege →](https://app.uslege.ai/bills/3248197)

HF 5156Prescription drug price tied to Medicare Drug Price Negotiation ProgramRestrictive

Caps in-state prices for select drugs at the federal Medicare-negotiated maximum fair price and imposes reimbursement rules on PBMs to align with that cap, with anti-withdrawal penalties on manufacturers.

**Sponsor:** Michael Howard (D–House (district not confirmed))**Status:** Introduced 2026-05-17, referred to Health Finance and Policy**Category:** Price caps / PBM reimbursement rules

[View on USLege →](https://app.uslege.ai/bills/3881704)

### Who testified: stakeholders on the record · 3 on the record

### Testified FOR PBMs (against new regulation) · for

Michelle Mack

Senior Director, Pharmaceutical Care Management Association (PCMA)

HF 1652

Testified in opposition to HF1652 on behalf of PBMs, arguing plans/PBMs need mid-year flexibility to respond to drug shortages, backorders and manufacturer price hikes, and that the bill lacked a drug-shortage exception.

### Testified AGAINST PBMs (for reform) · against

Dr. Laurel Reese

Family physician; Minnesota Medical Association

HF 1652

Testified for HF1652 (mid-year formulary lock-in bill) before House Health Finance and Policy, arguing patients who find an effective medication during open enrollment should not have a plan/PBM yank coverage or reclassify it mid-year for cost reasons.

Elliot Butai

Senior Policy Coordinator, NAMI Minnesota

HF 1652

Testified for HF1652, describing mid-year formulary/cost-sharing changes as a 'bait and switch' that is especially disruptive for people with mental illness who depend on medication stability, and urged the committee to hold plans/PBMs to the terms in place at enrollment.

### Hearing clips

[

![Hearing clip: MN (SF 1876: Michelle Kermans (Prime Therapeutics) (for)) PBM opposes formulary mandate bill](https://app.uslege.ai/api/clip-thumbnail/6035275d-f580-4177-9523-e104c1978b2d)▶

MN (SF 1876: Michelle Kermans (Prime Therapeutics) (for)) PBM opposes formulary mandate bill

Michelle Kermans, Government Affairs Principal/Registered Lobbyist, Prime Therapeutics (a Minnesota-headquartered PBM) · 2888-2994

“Our business model focuses on purpose beyond profits... our primary motivation is not to maximize profits. It is to do the right thing.”

Watch clip

](https://app.uslege.ai/share/6035275d-f580-4177-9523-e104c1978b2d?from=clips)[

![Hearing clip: MN (SF 3299: Sen. Alice Mann's amendment walkthrough (against)) Spread-pricing ban & fiduciary duty](https://app.uslege.ai/api/clip-thumbnail/a8246161-5d70-4ea9-89fc-c3a191066ecf)▶

MN (SF 3299: Sen. Alice Mann's amendment walkthrough (against)) Spread-pricing ban & fiduciary duty

Presenter of Sen. Alice Mann's amendment (Senate Health & Human Services committee counsel/staff walking through the bill on the record) · 4690-4840

“Three PBMs that control over 80% of the market are taking home over $10,000,000,000 in profits while our pharmacies are closing.”

Watch clip

](https://app.uslege.ai/share/a8246161-5d70-4ea9-89fc-c3a191066ecf?from=clips)

#33 of 48

#34

## New York

Most Restrictive

New York already operates under an existing PBM licensing/registration framework (Insurance Law Art. 29) and DFS spread-pricing restrictions from prior sessions, and the 2025-26 session is stacking further reform on top: S5464/A9045/A7357 (fair reimbursement, ban below-cost pay), A1722/S6161 (mandatory pass-through pricing, eliminate spread pricing), S6764 (annual rebate/financial-transaction disclosure to the Superintendent), and S9191/A9184 (three-year forced divestment of insurer-PBM-pharmacy cross-ownership). None of the current-session bills has been signed yet (all still 'REFERRED TO' committee as of Jan 2026), but the volume and reach of pending restrictions plus the pre-existing licensing/spread-pricing baseline puts NY firmly in reform-forward territory.

Freedom from Comprehensive Reform3/25

Few PBM Mandates3/20

Light Enforcement / No Fiduciary Duty4/20

Business-Model Freedom4/20

Limited Regulatory Reach4/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

Leroy Comrie

D · Dist. 14

SB 5464

Sponsors PBM reimbursement/fair-pricing bill banning below-cost pharmacy payment.

David Weprin

D · Dist. 24

AB 1722

Sponsors mandatory pass-through pricing bill eliminating PBM spread pricing.

Michelle Hinchey

D · Dist. 41

SB 9191

Sponsors forced divestment bill banning insurer-PBM-pharmacy common ownership.

Rodneyse Bichotte Hermelyn

D · Dist. 42

AB 7119

Sponsors mail-order disclosure/patient-choice bill limiting PBM steering to owned mail-order pharmacies.

**Why it matters:** NY is a heavily-regulating jurisdiction: even without a new 2025-26 signature, the pending cross-ownership divestment bill (S9191/A9184) and mandatory pass-through pricing bills (A1722/S6161) represent existential-level restructuring risk to the PBM model, marking it a top-tier state to watch.

### Bills

SB 5464Relates to reimbursement practices of pharmacy benefit managersRestrictive

Establishes PBM duties of care and transparency obligations, mandates fair-pricing appeals for pharmacies, prohibits reimbursing below acquisition cost, and requires timely MAC updates.

**Sponsor:** Leroy Comrie (D–14)**Status:** Referred to Health Committee (pending), 2025-26 session**Category:** Reimbursement mandate / spread-pricing ban

[View on USLege →](https://app.uslege.ai/bills/2160024)

AB 1722Relates to reducing pharmacy benefit manager costsRestrictive

Mandates a pass-through pricing model for PBM-insurer contracts, limiting PBM charges to actual cost plus a regulated administrative fee, banning spread pricing, and forcing state approval of any resulting premium changes.

**Sponsor:** David Weprin (D–24)**Status:** Referred to Insurance Committee (pending), 2025-26 session**Category:** Mandatory pass-through pricing

[View on USLege →](https://app.uslege.ai/bills/2126929)

AB 6764Relates to reporting requirements for pharmacy benefit managersRestrictive

Requires PBMs to file detailed annual reports with the Superintendent of Insurance disclosing aggregated and itemized manufacturer rebates, their disposition, and full rebate-contract terms.

**Sponsor:** David Weprin (D–24)**Status:** Referred to Insurance Committee (pending), 2025-26 session**Category:** Rebate/financial transparency mandate

[View on USLege →](https://app.uslege.ai/bills/2142208)

SB 9191Limitations on overlapping control between insurers, PBMs and pharmaciesRestrictive

Bars any entity from owning/controlling any combination of an insurer, PBM, and pharmacy in NY, forces a three-year divestment for existing violators, and empowers the Attorney General to enforce with civil penalties.

**Sponsor:** Michelle Hinchey (D–41)**Status:** Referred to Judiciary Committee (pending), 2025-26 session**Category:** Vertical-integration / ownership ban

[View on USLege →](https://app.uslege.ai/bills/3846734)

AB 7119Mail-order pharmacy disclosure / patient choiceRestrictive

Requires managed-care plans to annually disclose contracted mail-order pharmacies and confirms enrollees' right to fill mail-order prescriptions at any contracted retail pharmacy option.

**Sponsor:** Rodneyse Bichotte Hermelyn (D–42)**Status:** Referred to Health Committee (pending), 2025-26 session**Category:** Anti-mandatory-mail-order

[View on USLege →](https://app.uslege.ai/bills/2143209)

### Hearing clips

[

![Hearing clip: NY: S1618/A3236: Christopher Morton, NYU Law (against)](https://app.uslege.ai/api/clip-thumbnail/4d35e57f-a729-405a-aa13-7ddce845f2b6)▶

NY: S1618/A3236: Christopher Morton, NYU Law (against)

Christopher Morton, Associate Professor of Law, NYU School of Law (testifying pro bono for T1 International / NY Insulin for All) · 29990-30196

“Secretive, predatory, for-profit pharmacy benefit managers, or PBMs, are a particular problem, and we know that state governments can replace and regulate these companies with more transparent, lower-cost public options in pharmacy benefit management.”

Watch clip

](https://app.uslege.ai/share/4d35e57f-a729-405a-aa13-7ddce845f2b6?from=clips)

Only one clippable on-topic hearing found for this state; a second real clip was not available (no other on-topic hearing or opposition testimony).

#34 of 48

#33

## North Dakota

Most Restrictive

ND enacted HB 1584 this session: a comprehensive PBM licensing/oversight law creating a PBM enforcement fund, banning certain anti-competitive contracting practices, and mandating rebate/payment pass-through transparency, plus HB 1087 (mandatory administrator licensing for PBMs) and HB 1216 (accumulator-adjustment ban counting copay assistance toward out-of-pocket maximums): all signed into law. One partial offset: HB 1248 (enacted) requires cost-benefit analysis and initially limits any new health-benefit mandate to public-employee plans, creating friction against future PBM mandates.

Freedom from Comprehensive Reform3/25

Few PBM Mandates4/20

Light Enforcement / No Fiduciary Duty4/20

Business-Model Freedom3/20

Limited Regulatory Reach4/15

### Favor light-touch regulation · PBM-friendly

Robin Weisz

R · Dist. 14

HB 1248

Sponsored enacted bill requiring cost-benefit justification before any new PBM/insurance mandate, raising the bar against future reform.

### Favor PBM reform · reform-forward

Jim Kasper

R · Dist. 46

HB 1584

Sponsored the enacted comprehensive PBM licensing/enforcement-fund law.

Karen Karls

R · Dist. 35

HB 1216

Sponsored both the enacted PBM administrator-licensing law and the accumulator-ban law.

**Why it matters:** ND quietly became a fully regulated PBM state this cycle via HB 1584's licensing/enforcement-fund regime: now a compliance requirement rather than a live legislative fight, while HB 1248's mandate-offset rule stands as a friction point against further reform.

### Bills

HB 1584PBM Licensing, Enforcement Fund & Contracting PracticesRestrictive

Establishes comprehensive licensure and oversight of PBMs including a PBM enforcement fund, prohibits certain anti-competitive contracting practices, and mandates transparency that rebates/payments received are passed to covered entities or individuals.

**Sponsor:** Jim Kasper (R–46)**Status:** Enacted, filed with Secretary of State 04/28/2025**Category:** Comprehensive PBM licensure/enforcement

[View on USLege →](https://app.uslege.ai/bills/3308672)

HB 1087PBM Administrator LicensingRestrictive

Requires PBMs to hold an administrator license under the insurance code, sets application/renewal fees, and establishes grounds for denial, suspension, or revocation based on competency and conduct.

**Sponsor:** Karen Karls (R–35)**Status:** Enacted, filed with Secretary of State 03/14/2025**Category:** PBM licensure

[View on USLege →](https://app.uslege.ai/bills/3308175)

HB 1216Out-of-Pocket Expense Accumulator BanRestrictive

Requires health plans to count copay-assistance amounts toward enrollees' out-of-pocket maximum or cost-sharing requirements, banning PBM/plan accumulator-adjustment programs, and extends the rule to self-insurance plans.

**Sponsor:** Karen Karls (R–35)**Status:** Enacted, effective 01/01/2026**Category:** Accumulator-program restriction

[View on USLege →](https://app.uslege.ai/bills/3308309)

HB 1248Health Insurance Mandate Cost-Benefit AnalysisEnabling

Requires cost-benefit analysis before committee action on any new health-benefit mandate, limits new mandates initially to public-employee plans with an expiration date, and requires reporting before extension to broader insurance markets.

**Sponsor:** Robin Weisz (R–14)**Status:** Enacted, filed with Secretary of State 04/28/2025**Category:** Mandate-limiting procedural rule

[View on USLege →](https://app.uslege.ai/bills/3308334)

HB 1543Legislative Study: Prescription Drug PricingMixed-Monitor

Directs a 2025-26 interim legislative management study of federal maximum-fair-price drug pricing and PERS-covered drug overlap, reporting recommendations to the 70th Assembly.

**Sponsor:** Lisa Meier (R)**Status:** Study directed, filed with Secretary of State 03/26/2025**Category:** Drug-pricing study

[View on USLege →](https://app.uslege.ai/bills/3308623)

### Who testified: stakeholders on the record · 2 on the record

### Testified FOR PBMs (against new regulation) · for

No witnesses testified in support on the record.

### Testified AGAINST PBMs (for reform) · against

Mike Schwab

North Dakota Pharmacists Association

HB 1584

Told the Senate Industry and Business Committee the association was comfortable with the bill's funding mechanism and pushed back on litigation fears, noting the underlying pharmacy-code provisions being enforced have already been law (and litigated) for years: arguing the PBM licensing/enforcement-fund regime is on solid footing.

Jon Godfread

North Dakota Insurance Commissioner (ND Insurance Department)

HB 1584

As the regulator who would run the new PBM oversight division, walked the committee through the negotiated licensing/enforcement-fund amendments and requested flexible hiring authority (pharmacists, attorneys, examiners) to stand up PBM regulation from scratch.

### Hearing clips

Topic-keyword and bill-number/sponsor searches (HB 1584/1087/1216, Kasper/Karls) found no hearing tied to ND's three enacted PBM bills. The only PBM-critical testimony found (a citizen witness describing PBM formulary/kickback practices) was embedded in an unrelated pharmacist-scope-of-practice hearing (SB 2102, Joint Policy Committee): not honestly attributable to the tracked PBM legislation, so treated as a gap rather than stretched to fit.

#35 of 48

#35

## West Virginia

Most Restrictive

West Virginia enacted HB 5430 this session -- a comprehensive PBM regulatory overhaul requiring PEIA and Medicaid to competitively contract with pharmacy cost-containment vendors, mandating rebate pass-through, prohibiting certain PBM ownership structures and reimbursement practices, and imposing quarterly PBM reporting. Pending bills would extend the squeeze further: SB 907 caps PBM reimbursement/charges and bars PBM-owned-pharmacy contracts with PEIA/Medicaid; HB 5365 hands the Insurance Commissioner direct regulatory authority over PBMs serving PEIA; SB 1028 mandates counting copay assistance toward cost-sharing (accumulator ban); and HB 5149 would create a Prescription Drug Affordability Board with upper payment limits. The lone counterweight is HB 5109, which narrows the statutory PBM definition by removing claims processing from covered PBM duties.

Freedom from Comprehensive Reform3/25

Few PBM Mandates4/20

Light Enforcement / No Fiduciary Duty4/20

Business-Model Freedom3/20

Limited Regulatory Reach3/15

### Favor light-touch regulation · PBM-friendly

Matthew Rohrbach

R

HB 5109

Sponsored a bill narrowing the statutory PBM definition by removing claims processing, shrinking the scope of regulated PBM activity.

### Favor PBM reform · reform-forward

Evan Worrell

R

HB 5430

Lead sponsor of the enacted comprehensive PEIA/Medicaid PBM regulatory overhaul.

Brian Helton

R

SB 907

Sponsored the pending bill capping PBM reimbursement and barring PBM-owned-pharmacy state contracts.

David Green

R

HB 5365

Sponsored the bill giving the Insurance Commissioner direct regulatory authority over PBMs serving PEIA.

Patricia Rucker

R

SB 1028

Sponsored the copay-accumulator ban restricting PBM/insurer cost-sharing design.

Kayla Young

D

HB 5149

Sponsored the bill creating a Prescription Drug Affordability Board with upper payment limit authority.

**Why it matters:** West Virginia has enacted the HB 5430 licensing/rebate-pass-through regime for PEIA/Medicaid PBM contracts, now in force and shifting the state into a compliance posture; SB 907, HB 5365, SB 1028, and HB 5149 form the next possible wave of restrictions, while HB 5109's narrower PBM definition stands as a friction point.

### Bills

HB 5430Relating to pharmaceutical benefitsRestrictive

Requires PEIA and Medicaid to competitively contract with pharmacy cost-containment vendors, mandates transparency and rebate pass-through to reduce premiums, prohibits certain PBM ownership structures/reimbursement practices, and requires quarterly PBM reporting plus a dispensing-cost study.

**Sponsor:** Evan Worrell (R)**Status:** Enacted -- Chapter 250, Acts, Regular Session, 2026**Category:** Comprehensive PBM regulation (PEIA/Medicaid)

[View on USLege →](https://app.uslege.ai/bills/3845316)

SB 907Relating to pharmacy benefit managers and state pharmacy purchasingRestrictive

Caps PBM reimbursement and charges, bars contracts between PBM-owned pharmacies and state Medicaid/PEIA, mandates annual dispensing-fee studies, and requires cost-containment tools engaging prescribers.

**Sponsor:** Brian Helton (R)**Status:** To Health and Human Resources (pending), 2026 session**Category:** PBM reimbursement/ownership restriction

[View on USLege →](https://app.uslege.ai/bills/3844415)

HB 5365Relating to the regulation of pharmacy benefit managers providing services to PEIARestrictive

Grants the Insurance Commissioner regulatory authority over PBMs serving PEIA, establishes a special fraud investigation unit, and mandates detailed PBM contract-transparency and reporting requirements.

**Sponsor:** David Green (R)**Status:** To House Banking and Insurance (pending), 2026 session**Category:** PBM oversight authority

[View on USLege →](https://app.uslege.ai/bills/3841653)

SB 1028Relating to financial assistance available for prescription drugRestrictive

Requires insurers and PBMs to count all cost-sharing payments made by or on behalf of insureds toward deductibles/out-of-pocket limits and bars altering plan terms based on copay-assistance availability.

**Sponsor:** Patricia Rucker (R)**Status:** To Health and Human Resources (pending), 2026 session**Category:** Copay-accumulator ban

[View on USLege →](https://app.uslege.ai/bills/3852285)

HB 5109Update the regulation of pharmacy benefit managersEnabling

Amends the Pharmacy Audit Integrity Act's PBM definition to remove claims processing from what counts as pharmacy benefits management, narrowing the scope of activity subject to PBM regulation.

**Sponsor:** Matthew Rohrbach (R)**Status:** To House Health and Human Resources (pending), 2026 session**Category:** PBM definition narrowing

[View on USLege →](https://app.uslege.ai/bills/3833847)

HB 5149Establishing the West Virginia Prescription Drug Affordability BoardRestrictive

Creates a Prescription Drug Affordability Board and Stakeholder Council empowered to review drug costs and set upper payment limits on unaffordable drugs, funded by manufacturer/PBM-adjacent assessments.

**Sponsor:** Kayla Young (D)**Status:** To House Health and Human Resources (pending), 2026 session**Category:** Drug affordability board / price caps

[View on USLege →](https://app.uslege.ai/bills/3833908)

### Who testified: stakeholders on the record · 4 on the record

### Testified FOR PBMs (against new regulation) · for

Sean Stevenson

Senior Director, State Affairs, Pharmaceutical Care Management Association (PCMA)

HB 5430

Testified before Senate HHR (3/5/26) that PBMs are the only supply-chain entity working to lower drug costs, defended rebate/spread/admin-fee compensation as legitimate business models, and warned that restricting how PBMs are compensated limits the value they can pass on to plan sponsors.

Jessica Dobrinsky

Chief of Staff, Cardinal Institute for West Virginia Policy

HB 5430

Presented research to Senate HHR (3/5/26) framed as neutral showing WV's 2024 NADAC+dispensing-fee mandate produced adverse effects (a 52% cut in generic reimbursement, a 44% PEIA cost increase) and argued additional PBM regulatory layering onto state code would worsen the issue and should be avoided.

### Testified AGAINST PBMs (for reform) · against

Matt Walker

Director & Registered Lobbyist, West Virginia Independent Pharmacy Association

HB 5430

Testified in both House HHR (2/12/26) and Senate HHR (3/5/26) that PBM spread pricing, below-cost reimbursement, and GPO rebate-skimming are closing WV independent pharmacies (cited Fruit Pharmacy and others), and voiced WVIPA support for HB 5430's NADAC+dispensing-fee floor and its ban on PEIA/Medicaid contracting with PBM-owned pharmacies.

Devonna Miller West

Independent community pharmacist, Oceana, WV (36 years practicing)

HB 5430

Testified before Senate HHR (3/5/26) that manufacturer rebates/kickbacks to PBMs (e.g., ~$16,000 in 5 weeks on just 12 branded drugs at her one pharmacy) and below-cost reimbursement are driving independent pharmacies out of business, and urged the committee to pass the bill to make PBMs accountable.

### Hearing clips

Clip captured but thumbnail failed to render server-side after extended wait; dropped to keep the report honest.

#36 of 48

#36

## Alabama

Most Restrictive

Alabama enacted SB252, the Community Pharmacy Relief Act (Act, effective 2025-04-15), a comprehensive PBM law setting minimum independent-pharmacy reimbursement rates, banning unfair PBM practices, mandating rebate pass-through/transparency, and expanding Insurance Commissioner enforcement with penalties. The legislature followed up in the 2026 session with HB372 (enacted) adding dedicated PBM Division staff to the Department of Insurance, plus pending SB345 (parity for 'unaffiliated' pharmacies); the 2025 session's SB99 (PBM Licensure, Regulation, and Accountability Act) and SB93 (reimbursement-floor/audit reform) both died, with SB252 the enacted vehicle: but the reform momentum against the PBM business model is sustained.

Freedom from Comprehensive Reform3/25

Few PBM Mandates3/20

Light Enforcement / No Fiduciary Duty3/20

Business-Model Freedom4/20

Limited Regulatory Reach3/15

### Favor light-touch regulation · PBM-friendly

No sponsor-derived allies in the current slate.

### Favor PBM reform · reform-forward

William M. Beasley

D · Dist. 28

SB 252

Sponsored the enacted comprehensive PBM reform law (reimbursement floors, rebate pass-through, enforcement).

Larry Stutts

R · Dist. 6

SB 99

Sponsors both the pending PBM Licensure/Accountability Act and the follow-on unaffiliated-pharmacy parity bill.

Andrew Jones

R · Dist. 10

SB 93

Sponsored a bill banning below-cost PBM reimbursement and PBM fees on pharmacies.

**Why it matters:** Alabama is a hardened reform state: the comprehensive 2025 law is already in force and lawmakers are actively building out enforcement capacity and tightening loopholes (SB345) rather than revisiting the framework.

### Bills

SB 252Community Pharmacy Relief ActRestrictive

Establishes minimum reimbursement rates for independent pharmacies, prohibits certain unfair PBM practices, requires transparency and pass-through of manufacturer rebates, enhances Commissioner of Insurance oversight with penalties, and protects pharmacists from retaliation.

**Sponsor:** William M. Beasley (D–28)**Status:** Enacted**Category:** Reimbursement floor / rebate pass-through

[View on USLege →](https://app.uslege.ai/bills/1886042)

SB 99Alabama Pharmacy Benefits Manager Licensure, Regulation, and Accountability ActRestrictive

Enhances Department of Insurance regulation of PBMs, sets pharmacy reimbursement benchmarks, restricts steering patients to specific pharmacies/drugs, regulates audit and recoupment processes, and authorizes civil actions for violations.

**Sponsor:** Larry Stutts (R–6)**Status:** Pending Committee Action in House of Origin**Category:** Licensure / anti-steering

[View on USLege →](https://app.uslege.ai/bills/1885957)

SB 93Pharmacy Benefits Managers; additional regulation of practicesRestrictive

Bars PBMs from reimbursing below actual acquisition/dispensing cost, bans certain fees charged to pharmacies, allows pharmacists to disclose price information, and empowers the Commissioner of Insurance to enforce compliance.

**Sponsor:** Andrew Jones (R–10)**Status:** Pending Committee Action in House of Origin**Category:** Reimbursement floor / fee bans

[View on USLege →](https://app.uslege.ai/bills/1885895)

SB 345PBM regulation; 'unaffiliated' pharmacy parityRestrictive

Replaces 'independent pharmacy' with 'unaffiliated pharmacy,' establishes reimbursement parity between unaffiliated and PBM-affiliated pharmacies, prohibits discriminatory PBM practices, and sets fee/claims standards for PBM networks.

**Sponsor:** Larry Stutts (R–6)**Status:** Pending Committee Action in House of Origin**Category:** Anti-affiliate-steering

[View on USLege →](https://app.uslege.ai/bills/3860900)

HB 372Dept. of Insurance PBM Division; exempt personnelMixed-Monitor

Authorizes two exempt personnel within the Department of Insurance's Pharmacy Benefits Manager Division to staff the state's PBM oversight function, effective June 1, 2026.

**Sponsor:** Phillip Rigsby (R)**Status:** Enacted**Category:** Enforcement capacity

[View on USLege →](https://app.uslege.ai/bills/3834431)

SJR 45PBM practices studyMixed-Monitor

Directs the Legislative Services Agency to retain a national consultant to study PBM practices' effects on drug costs, pharmacy operations, and consumer access, with findings due December 1, 2025.

**Sponsor:** Tom Butler (R)**Status:** Enacted**Category:** Study/monitoring

[View on USLege →](https://app.uslege.ai/bills/1896223)

### Hearing clips

[

![Hearing clip: AL (HB372: Sen. Butler (against)) "PBM stands for pretty bad medicine"](https://app.uslege.ai/api/clip-thumbnail/3c72afd1-a334-4dcc-b253-225bab3bc321)▶

AL (HB372: Sen. Butler (against)) "PBM stands for pretty bad medicine"

Sen. Butler, Alabama Senate (floor) · 26709-26795

“I want them to know that I support them just as I did the PBM bills, and that because I believe in my rural pharmacist. I'm gonna tell you my definition of PBM, why they need to be regulated. PBM stands for pretty bad medicine.”

Watch clip

](https://app.uslege.ai/share/3c72afd1-a334-4dcc-b253-225bab3bc321?from=clips)

Only one clippable on-topic hearing found for this state; a second real clip was not available (no other on-topic hearing or opposition testimony).

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## Frequently asked

Which states regulate PBMs most heavily?

Louisiana and Arkansas score lowest in this report, at 8 out of 100 apiece, each having enacted a stack of comprehensive PBM reform laws in the 2025-2026 sessions covering reimbursement floors, anti-steering and ghost-network bans, licensure, and enforcement funds.

Which states regulate PBMs the least?

Wyoming, South Dakota, and New Hampshire score highest, having introduced no PBM-specific legislation in their 2025 or 2026 sessions.

What does this score actually measure?

A 0-100 PBM regulatory-freedom index built from five weighted factors: freedom from comprehensive reform, few PBM mandates, light enforcement and no fiduciary duty, business-model freedom, and limited regulatory reach. A lower score means a state has enacted heavier PBM regulation; a higher score means PBMs there operate with fewer statutory mandates.

Where does this data come from?

Bill-level data comes from USLege's live legislative tracking database, covering 255 bills across 48 scored states through mid-July 2026. Montana and Nevada have essentially no indexed PBM bill activity in USLege and are shown gray, unscored, rather than assigned a score.

Browse more state-by-state legislative data in the [full reports index](/reports).
