Kentucky’s SB 188 (2024) set a clear NADAC floor. For plan contracts issued or renewed on or after January 1, 2025, a PBM must reimburse at no less than the most recent monthly NADAC — or the wholesale acquisition cost where NADAC is not available — plus a professional dispensing fee.
For retail independent pharmacies, that dispensing fee is at least $10.64 until plan years beginning January 1, 2027, when a periodic cost-of-dispensing survey takes over. Reconciliation or “effective-rate” clawbacks that pull reimbursement below the floor are prohibited. Reimbursement appeals run through Kentucky’s existing MAC appeals statute, KRS 304.17A-162.