PBM Reimbursement Tracker
What does your state require?
A plain-language, source-cited entry for each state — the reimbursement basis, the effective date, and the appeal route. Every entry links the primary statute or agency it rests on.
Each state is shaded by what its PBM reimbursement law requires — tap a tracked state for the detail.
AK ME VT NH WA ID MT ND MN WI MI NY RI MA OR NV WY SD IA IL IN OH PA NJ CT CA UT CO NE MO KY WV VA MD DE AZ NM KS AR TN NC SC DC OK LA MS AL GA HI TX FL
| State | Status | Reimbursement basis | Effective | |
|---|---|---|---|---|
| Alabama | Enacted | A PBM may not reimburse for dispensing a prescription drug in an amount less than the Medicaid reimbursement rate in effect on the act's effective date — Alabama's Medicaid drug benchmark plus the Medicaid professional dispensing fee — and may not claw back below that floor. Drugs paid for by the Medicaid program are carved out. | Floor effective October 1, 2025 (signed April 15, 2025) | View → |
| Alaska | Partially enacted | No reimbursement floor. PBMs must keep MAC lists current and disclose NADAC and WAC, may not reimburse a pharmacy less than they pay an affiliate for the same service (anti-self-dealing parity), and may not use spread pricing. NADAC appears only as a disclosure field, not a payment floor. | January 1, 2025 (MAC appeal in force since July 1, 2019) | View → |
| Arizona | Partially enacted | No reimbursement floor. PBMs must update MAC price and drug information every seven business days, disclose the sources used to determine MAC pricing, and establish a process for a network pharmacy (or its PSAO) to appeal MAC-based reimbursement. | January 1, 2020 | View → |
| Arkansas | Enacted | Prohibits MAC reimbursement below the pharmacy's acquisition cost (wholesaler invoice price); MAC lists must be updated within 7 days of a qualifying cost increase | Signed April 1, 2015; upheld by the U.S. Supreme Court in Rutledge v. PCMA (8–0, Dec. 10, 2020) | View → |
| California | Partially enacted | No reimbursement floor. A PBM must use a pass-through pricing model (plan payments equal pharmacy payments), is barred from spread pricing and from retroactive reductions of payment for pharmacist services (clawbacks), and owes a fiduciary duty to payer clients; steering to affiliated pharmacies is curbed. | Core provisions operative January 1, 2026 (signed October 11, 2025) | View → |
| Colorado | Partially enacted | No NADAC or acquisition-cost floor; MAC-list sourcing and transparency rules only | MAC regime in effect; HB 1094 flat-fee model effective 2027 | View → |
| Connecticut | Partially enacted | No reimbursement floor. On and after January 1, 2026, a PBM must offer a health plan the option of being charged the same price the PBM pays a pharmacy for a prescription drug — a pass-through option, not a mandate to pay pharmacies at NADAC or above acquisition cost. MAC protections sit in Connecticut's existing PBM statutes. | Pass-through option effective January 1, 2026 | View → |
| Delaware | Partially enacted | No reimbursement floor. PBMs must keep transparent MAC lists, may not pay a pharmacy less than they pay an affiliate for the same goods or services (anti-self-dealing parity), and a pharmacy may decline to dispense when reimbursement is below its acquisition cost — a right to refuse, not a payment mandate. | October 26, 2021 | View → |
| District of Columbia | Partially enacted | No reimbursement floor and no MAC pricing/appeal statute. A PBM owes a fiduciary duty to the covered entity, must disclose conflicts of interest, and must pass through manufacturer payments and rebates in full. District Medicaid sets its own pharmacy reimbursement separately. | 2004 | View → |
| Florida | Partially enacted | No reimbursement floor. PBMs must use a pass-through pricing model, may not retain spread (unless the entire spread is passed to the plan), and may not impose clawbacks or reconciliation offsets. A dispensing fee is defined but no minimum amount is set. | July 1, 2023 (employer-sponsored coverage from January 1, 2024) | View → |
| Georgia | Partially enacted | A reimbursement floor is in force for state health plans only: NADAC on the day of claim adjudication (or a discounted AWP/WAC if NADAC is unavailable) plus a professional dispensing fee of at least $10.50 for chain pharmacies and $11.50 for independents, with an anti-circumvention clause. A broader commercial floor (HB 810, NADAC + $10.64) has not passed. | State-plan floor effective January 1, 2026 | View → |
| Hawaii | Partially enacted | No reimbursement floor. PBMs must review and update the MAC of each listed drug at least once every seven days using the most recent data, applying the update the same day, and must maintain a MAC appeals process. | In force (current codified version) | View → |
| Idaho | Partially enacted | No commercial reimbursement floor. PBMs must use pass-through pricing (spread pricing prohibited), meet network-adequacy and anti-steering requirements, and provide a MAC appeals process. Acquisition cost appears only as the level a MAC must be reset to if a generic-drug appeal is upheld — not a guaranteed payment floor. | January 1, 2025 | View → |
| Illinois | Partially enacted | No reimbursement floor. The enacted law bans spread pricing, limits steering to PBM-affiliated pharmacies, requires 100% rebate pass-through, and adds PBM registration plus a per-covered-life fee funding a pharmacy-grant program. A NADAC + $10.49 floor bill (HB 4548) did not pass. | Signed July 1, 2025; most provisions effective January 1, 2026 | View → |
| Indiana | Enacted | The greater of the PBM's affiliated-pharmacy rate or NADAC plus the Medicaid professional dispensing fee (acquisition cost plus a fair dispensing fee for liquor-permit pharmacies) | Applies to policies or contracts issued, renewed, or amended after December 31, 2025 (effective January 1, 2026) | View → |
| Iowa | Enacted | No less than NADAC (or WAC where NADAC is unavailable) for Iowa retail pharmacies | July 1, 2025 (enforcement partially enjoined as to ERISA-plan plaintiffs) | View → |
| Kansas | Partially enacted | No reimbursement floor; MAC-list construction and update rules only | MAC list/appeal requirements in effect; PBM licensure effective January 1, 2023 | View → |
| Kentucky | Enacted | No less than NADAC (or WAC where NADAC is unavailable), using the most recent monthly NADAC; reconciliation clawbacks below this are prohibited | Applies to PBM contracts issued, renewed, extended, or amended on or after January 1, 2025 | View → |
| Louisiana | Enacted | No reimbursement below acquisition cost, defined as NADAC; PBMs must use a NADAC-based reimbursement formula plus a professional dispensing fee | January 1, 2026 (the 2024 SB 444 acquisition-cost floor took effect Jan 1, 2025 and is superseded) | View → |
| Maine | Enacted | Payment must be ingredient cost plus a dispensing fee, less cost-sharing; ingredient cost may not exceed MAC or average wholesale price | 2019 | View → |
| Maryland | Partially enacted | Commercial: no NADAC floor; a PBM may not pay a pharmacy less than it pays its own affiliate. Medicaid: at least NADAC plus the Medicaid professional dispensing fee | Commercial MAC rules effective 2020; Medicaid below-NADAC reporting from January 1, 2022 | View → |
| Massachusetts | Partially enacted | No reimbursement floor. Massachusetts licenses PBMs, requires MAC pricing updates at least every 7 days with a MAC appeals process, mandates cost and pricing reporting, and caps consumer cost-sharing on certain drugs. Spread pricing is disclosed but not banned. | PBM licensure required by January 1, 2026 | View → |
| Michigan | Partially enacted | A floor applies to Medicaid managed care only. For pharmacies with seven or fewer outlets, a Medicaid plan or PBM must pay the lesser of NADAC plus the Medicaid professional dispensing fee, WAC plus that fee, or the usual-and-customary charge — and the PBM (or PSAO) may not take any part of the dispensing fee. No commercial floor exists. | Methodology effective February 13, 2024 | View → |
| Minnesota | Partially enacted | Commercial: no acquisition-cost floor (MAC transparency only). Medicaid: lesser of NADAC or actual acquisition cost, plus the Medicaid professional dispensing fee | Commercial MAC regime since January 1, 2020; Medicaid NADAC floor effective January 1, 2027 (interim $4.50 dispensing payment from July 1, 2025) | View → |
| Mississippi | Enacted | Acquisition-cost floor enforced through appeals (PBM must pay at least the pharmacy's acquisition cost on a successful appeal); no below-affiliate reimbursement | January 1, 2021 | View → |
| Missouri | Partially enacted | No reimbursement floor. PBMs must reimburse MAC-priced drugs at pricing updated to reflect market pricing at least every 7 days, provide a MAC appeal, and disclose conflicts of interest; patient cost-sharing is capped at the lesser of copay or cash price. | 376.388 effective 2016; 376.387 as amended effective 2020 | View → |
| Montana | Enacted | No less than NADAC (the price in effect the day the claim was billed) plus a professional dispensing fee; if no NADAC is published, 100% of WAC plus the fee | Applies to conduct on or after October 1, 2025 (sunsets June 30, 2029) | View → |
| Nebraska | Partially enacted | A floor applies to Medicaid only. Nebraska Medicaid (fee-for-service and managed care) must reimburse small independent pharmacies — those owning six or fewer pharmacies — on the state's NADAC-based fee-for-service basis plus a professional dispensing fee, set at $10.38 per prescription until a biennial cost-of-dispensing survey replaces it. There is no commercial floor. | Beginning fiscal year 2024-25 | View → |
| Nevada | Partially enacted | No reimbursement floor and no MAC pricing/appeal statute. Nevada imposes a PBM fiduciary duty to the plan, conflict-of-interest disclosure, and anti-gag/transparency rules, and bars charging a patient a copay greater than the amount paid to the pharmacy. SB 389 (2025) requires Medicaid to use a single PBM — barred from spread pricing — by 2030. | PBM conduct rules in force; SB 389 single-PBM by January 1, 2030 | View → |
| New Hampshire | Partially enacted | No reimbursement floor. PBM contracts must disclose the sources used to calculate drug-product reimbursement and the national pricing compendia used for drug-price data, and must include a MAC appeals process. A NADAC point-of-reference bill (HB 1580) was killed in 2022. | January 1, 2020 | View → |
| New Jersey | Pending | Would create a floor of NADAC plus the state Medicaid professional dispensing fee of $10.92, require equal reimbursement across contracted pharmacies regardless of affiliation, impose PBM fiduciary duties, and decouple PBM pay from rebates. Passed the Assembly May 18, 2026; not yet signed. | Not yet in force | View → |
| New Mexico | Partially enacted | Reimbursement must be based on objective, verifiable sources and no less than what the PBM pays its own affiliate; no NADAC or acquisition-cost floor | July 1, 2023 | View → |
| New York | Pending | No reimbursement floor currently in force (the proposed NADAC + dispensing-fee floor was withdrawn from the 2024 rule). Pending S5939 would require at least NADAC, or acquisition cost if greater, plus the Medicaid professional dispensing fee | DFS market-conduct rules effective November 27, 2024; S5939 floor would take effect January 1, 2026 if signed | View → |
| North Carolina | Enacted | Reimbursement rates for an independent pharmacy, or any pharmacy in a pharmacy desert, must be at a minimum the acquisition cost for the covered drug, device, or service. PBMs also may not pay a pharmacy less than they pay a PBM affiliate for the same service, and rebate pass-through and audit protections apply. | October 1, 2025 (for contracts entered, renewed, or amended on or after that date) | View → |
| North Dakota | Partially enacted | No acquisition-cost or NADAC floor; MAC prices may not be set below the PBM's own pricing sources, and dispensing fees are excluded from the MAC calculation | MAC statute in effect; HB 1584 effective April 29, 2025 (licensing provision January 1, 2026) | View → |
| Ohio | Partially enacted | No commercial reimbursement floor. Ohio bans Medicaid spread pricing and reimburses Medicaid pharmacy through a single PBM on a NADAC-based fee-for-service rate; the 2026 law adds PBM licensure, fiduciary duty to the insurer, transparency, and audit authority. An affiliate-parity rate protection was removed before passage, leaving no commercial floor. | Licensure effective July 1, 2027; Medicaid spread-pricing ban in effect since 2019 | View → |
| Oklahoma | Partially enacted | No NADAC or acquisition-cost floor; PBM may not reimburse an independent less than a PBM-affiliated pharmacy; spread pricing prohibited | MAC/appeal provisions in effect; 2025 spread-pricing and transparency amendments effective in 2025 | View → |
| Oregon | Partially enacted | No across-the-board reimbursement floor. PBMs must be licensed, use pass-through pricing (no spread), meet network-adequacy and any-willing-pharmacy rules, and provide a MAC appeal; a pharmacy may appeal when reimbursement is less than the net amount it paid the supplier. The state medical-assistance (Medicaid) program is excluded from this section. | January 1, 2025 | View → |
| Pennsylvania | Partially enacted | No reimbursement floor. Act 77 expands PBM registration, transparency, network-adequacy, and anti-steering rules for fully-insured plans and directed the Insurance Department to study a NADAC-plus-dispensing-fee model — but did not enact a floor. MAC transparency and appeals sit in the existing Pharmacy Audit Integrity and Transparency Act. | Signed July 17, 2024 (provisions staggered through 2026) | View → |
| Rhode Island | Partially enacted | No reimbursement floor. PBMs must disclose the basis of MAC lists, update MAC pricing, ensure listed drugs are appropriately rated and available, and include a MAC appeal process in every PBM-pharmacy contract. A 2024 NADAC-floor bill (S 2395) died in committee. | In force | View → |
| South Carolina | Pending | No floor in force yet. Pending bills would prohibit reimbursement below 104% of NADAC plus a professional dispensing fee no less than the South Carolina Medicaid dispensing fee, with WAC as a fallback where NADAC is unavailable, and an enhanced fee for low-volume pharmacies. | Not yet in force | View → |
| South Dakota | Partially enacted | No reimbursement floor tied to drug cost. A PBM may not reimburse an in-state pharmacy less than it reimburses a PBM affiliate for dispensing the same drug, calculated per unit (anti-self-dealing parity). PBMs must keep MAC lists transparent (with updates on price increases) and may not charge pharmacies certain fees. | 2023 | View → |
| Tennessee | Enacted | No reimbursement below the pharmacy's documented actual acquisition cost; spread pricing prohibited | Below-cost reimbursement and appeal provisions effective January 1, 2023 | View → |
| Texas | Partially enacted | No reimbursement floor; MAC-list construction and update rules only | MAC/appeal regime in effect since 2015 | View → |
| Utah | Partially enacted | No reimbursement floor tied to drug cost. A PBM must reimburse a network pharmacy, in aggregate, no less than it reimburses an affiliate for the same or equivalent service (anti-self-dealing parity). HB 527 (2026) adds MAC-list rules, a MAC appeals process, and a spread-pricing ban. | Affiliate parity since May 12, 2020; HB 527 effective May 6, 2026 | View → |
| Vermont | Partially enacted | No reimbursement floor tied to drug cost. A PBM may not reimburse an in-state pharmacy less than it reimburses a PBM affiliate for the same pharmacist services (anti-self-dealing parity), must keep MAC pricing transparent (updated at least every 7 calendar days), and may not use spread pricing. | July 1, 2024 | View → |
| Virginia | Partially enacted | No reimbursement floor tied to drug cost. A PBM may not reimburse a pharmacy less than it pays a PBM affiliate for the same pharmacist services, per unit (anti-self-dealing parity), and must keep MAC pricing transparent with a MAC appeal. ERISA self-funded plans, Medicaid, and Medicare Part D are excluded. | MAC provisions since January 1, 2016; PBM conduct rules since 2020 | View → |
| Washington | Partially enacted | No statutory reimbursement floor. Small/independent pharmacies (15 or fewer retail locations) on fully-insured commercial plans may appeal reimbursement that falls below the pharmacy's actual drug acquisition cost; the PBM must reconsider, and the Insurance Commissioner can review. Self-funded ERISA plans are excluded. | RCW 48.200.280 effective January 1, 2026; the appeals program is operating now | View → |
| West Virginia | Enacted | No less than NADAC plus a $10.49 professional dispensing fee (or WAC plus $10.49 where NADAC is unavailable) | January 1, 2022 | View → |
| Wisconsin | Partially enacted | No reimbursement floor. PBMs must update MAC pricing at least every 7 business days, give pharmacies a way to review updates, and provide a MAC appeal; on a successful appeal the PBM must identify an NDC available at or below MAC and adjust pricing. NADAC-plus floor bills (2024 and 2025) did not pass. | January 1, 2022 | View → |
| Wyoming | Partially enacted | No reimbursement floor. To place a drug on a MAC list, the PBM must ensure it is appropriately rated and generally available for purchase by retail pharmacies in the state, and may consider only the price of that drug and therapeutic equivalents in setting MAC. A MAC appeal and audit-appeal protections apply. | 2016 (amended through 2023) | View → |
Coverage is expanding. A state not listed yet does not mean it has no law — only that its entry is not yet published. See how entries are compiled.