State Tracker Updated June 15, 2026

Michigan: what the PBM reimbursement law requires

Michigan sets a reimbursement floor for small pharmacies — but only in Medicaid managed care. There is no commercial floor; the state's commercial PBM law is licensure and conduct only.

Status	Partially enacted
Law	Public Act 279 of 2023 (HB 4276) — MCL 400.105i
Effective date	Methodology effective February 13, 2024
Reimbursement basis	A floor applies to Medicaid managed care only. For pharmacies with seven or fewer outlets, a Medicaid plan or PBM must pay the lesser of NADAC plus the Medicaid professional dispensing fee, WAC plus that fee, or the usual-and-customary charge — and the PBM (or PSAO) may not take any part of the dispensing fee. No commercial floor exists.
Professional dispensing fee	Set by reference to the Michigan Medicaid professional dispensing fee, not a fixed figure in this statute

Michigan does have a reimbursement floor — but it is limited to Medicaid managed care. Under MCL 400.105i (Public Act 279 of 2023, methodology effective February 13, 2024), a Medicaid managed-care plan or its PBM must reimburse pharmacies with seven or fewer outlets at the lesser of NADAC plus the Medicaid professional dispensing fee, WAC plus that fee, or the usual-and-customary charge, and may not skim any part of the dispensing fee.

This floor does not reach commercial plans. Michigan’s commercial PBM statute (the 2022 licensure act) governs PBM licensure and conduct, not a commercial reimbursement floor, which is why Michigan is shown here as partially enacted.

Sources

MCL 400.105i — Michigan Legislature (codified) Primary source
MDHHS Numbered Letter L-23-74 — pharmacy reimbursement methodology / effective date Primary source

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