Pharmacists for Fair Reimbursement What your state's PBM laws actually mean for community pharmacies
Explainer Updated June 15, 2026

How does an independent pharmacy appeal a PBM's reimbursement?

A MAC appeal is the formal process by which a pharmacy challenges a pharmacy benefit manager's reimbursement for a generic drug priced below what the pharmacy paid to acquire it. Most states with PBM laws now require PBMs to offer an appeals procedure with a defined filing window, but the deadline, the evidence required, and what the PBM must do if the appeal succeeds vary by state and by PBM.

A maximum allowable cost (MAC) is the ceiling a pharmacy benefit manager (PBM) will reimburse for a given generic drug. When that ceiling is set below what a pharmacy actually paid its wholesaler, the pharmacy dispenses at a loss. A MAC appeal is the mechanism for challenging that specific reimbursement.

What an appeal generally involves

The details are set by state law and by each PBM’s own procedure, but the common shape is:

  1. A filing window. Many state laws require the PBM to accept an appeal within a set number of business days of the claim — the exact window is one of the things that varies most by state.
  2. Evidence of acquisition cost. The pharmacy typically must show what it paid (for example, a wholesaler invoice) to demonstrate the MAC is below cost.
  3. A decision and a remedy. If the appeal succeeds, the law may require the PBM to adjust the MAC, and in some states to do so for other similarly situated pharmacies — not just for the single claim.

Why the state rules matter

Because the filing deadline, the evidence standard, and the remedy all turn on state law, the practical answer to “how do I appeal?” depends on where the pharmacy is. The State Tracker sets out, per state, whether an appeals procedure is required and the reimbursement floor it sits alongside. For the precise procedure, a pharmacy should always check the current statute and the specific PBM’s appeal instructions.

Other views — and our response

PBMs say maximum allowable cost (MAC) lists reflect a competitive market price for generics, and that an appeals process already gives pharmacies a fair route to correct genuine errors. (NCPA)
An appeals route does exist in most states, and that is a real safeguard. Pharmacies' concern is with how it works in practice: filing windows can be short, the burden is on the pharmacy to document its acquisition cost, and a successful appeal may only correct a single claim rather than the underlying price. That is why the state-by-state rules on deadlines and remedies matter so much.

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