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

New York: what the PBM reimbursement law requires

New York regulates PBM conduct, licensing and transparency (Department of Financial Services rules effective November 27, 2024) but does not yet impose a NADAC or acquisition-cost reimbursement floor — a proposed floor was withdrawn from the 2024 regulation. A floor bill (S5939) has passed both legislative chambers and awaits the Governor.

Status Pending
Law Insurance Law §§ 2902–2904 + DFS PBM regulations (enacted); S5939 (reimbursement floor, pending)
Effective date DFS market-conduct rules effective November 27, 2024; S5939 floor would take effect January 1, 2026 if signed
Reimbursement basis No reimbursement floor currently in force (the proposed NADAC + dispensing-fee floor was withdrawn from the 2024 rule). Pending S5939 would require at least NADAC, or acquisition cost if greater, plus the Medicaid professional dispensing fee
Professional dispensing fee Not specified in current law; pending bill would tie it to the state Medicaid dispensing fee
Appeal route No NADAC-floor appeal regime in force; the 2024 DFS rules govern PBM contracting and retroactive-adjustment conduct

New York has an enacted PBM conduct and transparency regime — Department of Financial Services rules effective November 27, 2024 cover licensing, contracting, and consumer protections — but it does not currently set a reimbursement floor. A proposed NADAC-plus-dispensing-fee floor was specifically withdrawn from the 2024 regulation before adoption.

A statutory floor (S5939) would require PBMs to pay at least NADAC — or acquisition cost if greater — plus the state Medicaid professional dispensing fee. As of this entry it has passed both legislative chambers but has not been signed into law, so it is tracked here as pending, not in force.

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