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

Illinois: what the PBM reimbursement law requires

Illinois bans PBM spread pricing, restricts steering, requires full rebate pass-through, and adds PBM registration and a per-member fee — but it does not create a NADAC reimbursement floor or a $10.49 dispensing fee.

Status Partially enacted
Law Prescription Drug Affordability Act — Public Act 104-0027 (HB 1697, 2025)
Effective date Signed July 1, 2025; most provisions effective January 1, 2026
Reimbursement basis 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.
Professional dispensing fee Not specified in statute (the $10.49 figure was in a separate bill that did not pass)

Illinois enacted a substantial PBM law in 2025 (the Prescription Drug Affordability Act, Public Act 104-0027), but it is not a reimbursement-floor law. It bans spread pricing, restricts steering to affiliated pharmacies, requires full rebate pass-through, and adds PBM registration and a per-member fee that funds a pharmacy-grant program.

A separate bill that would have required reimbursement at NADAC plus a $10.49 dispensing fee (HB 4548) did not pass. So while Illinois is often described as a floor state, the in-force law sets no NADAC floor and no statutory dispensing fee; a successor floor bill remains pending.

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