State Tracker Updated June 15, 2026

California: what the PBM reimbursement law requires

California's SB 41 forces PBMs onto a pass-through pricing model, bans spread pricing and retroactive reimbursement cuts, and imposes fiduciary duties — but it does not set a NADAC or acquisition-cost reimbursement floor.

Status	Partially enacted
Law	SB 41 (2025) — Health & Safety Code §§ 1385.0026–1385.0034; Insurance Code § 10123.2045
Effective date	Core provisions operative January 1, 2026 (signed October 11, 2025)
Reimbursement basis	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.
Professional dispensing fee	Not specified in statute (a pass-through professional dispensing fee may be contracted, but no amount is set)

California’s SB 41 (operative January 1, 2026) reshapes how PBMs price drugs but does not guarantee a reimbursement floor. It requires PBMs to use a pass-through pricing model — so what the plan pays equals what the pharmacy is paid — and bans spread pricing and retroactive cuts to pharmacist-service payments.

The law also imposes fiduciary duties on PBMs toward their payer clients and limits steering to affiliated pharmacies. None of these provisions set a per-claim minimum tied to NADAC or acquisition cost, so California is classified here as regulating PBM conduct rather than setting a floor.

Sources

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