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

Colorado: what the PBM reimbursement law requires

Colorado requires PBMs to maintain transparent, wholesaler-available MAC lists and to provide a MAC appeals process with a 21-day filing window, but sets no NADAC or acquisition-cost reimbursement floor. A separate enacted reform (HB 1094) moves PBM compensation toward a flat-fee model effective 2027.

Status Partially enacted
Law C.R.S. § 10-16-122.6 (MAC); § 10-16-122.5 (audit appeals); HB 1094 (flat-fee model)
Effective date MAC regime in effect; HB 1094 flat-fee model effective 2027
Reimbursement basis No NADAC or acquisition-cost floor; MAC-list sourcing and transparency rules only
Professional dispensing fee Not specified in the MAC statute
Appeal route Pharmacy has 21 days to appeal following the initial claim; the appeal must be investigated and resolved within 21 days, with adjustments no later than 1 day after the determination

Colorado regulates MAC-list sourcing and transparency and provides a robust appeal — 21 days to file, 21 days to resolve — but § 10-16-122.6 does not require reimbursement at NADAC or above acquisition cost. Drugs on a MAC list must be “generally available for purchase” from a national or regional wholesaler in the state.

Separately, Colorado has enacted a reform (HB 1094) that moves PBM compensation toward a flat-fee model effective 2027 — a different approach to the problem than a NADAC reimbursement floor.

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