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

Maryland: what the PBM reimbursement law requires

For commercial plans, Maryland requires MAC-pricing transparency, a 21-day MAC appeal plus an Insurance Commissioner complaint route, and bars a PBM from paying a pharmacy less than it pays its own affiliate — but sets no NADAC floor. Maryland's NADAC-plus-dispensing-fee floor applies to the Medicaid program.

Status Partially enacted
Law Md. Insurance § 15-1628.1 (MAC) and § 15-1612 (anti-self-dealing); Md. Health-General §§ 15-118 / 15-148 (Medicaid NADAC floor)
Effective date Commercial MAC rules effective 2020; Medicaid below-NADAC reporting from January 1, 2022
Reimbursement basis Commercial: no NADAC floor; a PBM may not pay a pharmacy less than it pays its own affiliate. Medicaid: at least NADAC plus the Medicaid professional dispensing fee
Professional dispensing fee Commercial: not specified. Medicaid: the state Medicaid professional dispensing fee
Appeal route Pharmacy must file a MAC appeal within 21 days; PBM must resolve within 21 days; after the internal appeal, a complaint may be filed with the Insurance Commissioner

Maryland’s commercial PBM rules require MAC-pricing transparency, a 21-day MAC appeal with a resolution within 21 days, and a follow-on complaint route to the Insurance Commissioner. A PBM also may not pay a pharmacy less than it pays its own affiliate for the same product or service. There is, however, no commercial NADAC floor.

Maryland’s NADAC-plus-dispensing-fee reimbursement floor sits in the Medicaid program (Health-General), where minimum reimbursement is at least NADAC for the generic product plus the Medicaid professional dispensing fee, with PBMs reporting any below-NADAC reimbursements.

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