State Tracker Updated June 15, 2026

Florida: what the PBM reimbursement law requires

Florida's 2023 Prescription Drug Reform Act requires PBM pass-through pricing, bans spread pricing and clawbacks, and gives pharmacies a 30-business-day MAC appeal — but it sets no NADAC or acquisition-cost reimbursement floor.

Status	Partially enacted
Law	Prescription Drug Reform Act — Ch. 2023-29 (SB 1550), Fla. Stat. § 626.8825
Effective date	July 1, 2023 (employer-sponsored coverage from January 1, 2024)
Reimbursement basis	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.
Professional dispensing fee	Not specified in statute
Appeal route	Pharmacy has at least 30 business days to file; PBM responds within 30 business days; if upheld, MAC is corrected up to at least the pharmacy's acquisition cost, with reverse-and-rebill

Florida’s Prescription Drug Reform Act (SB 1550, effective July 1, 2023) regulates PBM pricing without setting a reimbursement floor. It requires pass-through pricing, bans spread pricing unless the full spread is passed to the plan, and prohibits clawbacks and post-adjudication reconciliation offsets.

Pharmacies also get a strong MAC appeal: at least 30 business days to file, a 30-business-day response window, and — if the appeal is upheld — a MAC corrected up to at least the pharmacy’s acquisition cost with the ability to reverse and rebill. The law does not, however, guarantee a minimum reimbursement tied to NADAC or acquisition cost.

Sources

SB 1550 — Florida Senate (enrolled text) Primary source
Florida Office of Insurance Regulation — Pharmacy Benefit Managers Primary source

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