State Tracker Updated June 15, 2026

Pennsylvania: what the PBM reimbursement law requires

Pennsylvania's Act 77 of 2024 strengthens PBM registration, transparency, network-adequacy, and anti-steering rules, and ordered a study of a NADAC-plus-dispensing-fee model — but it did not enact a reimbursement floor.

Status	Partially enacted
Law	Act 77 of 2024 (HB 1993) — Pharmacy Benefit Reform Act
Effective date	Signed July 17, 2024 (provisions staggered through 2026)
Reimbursement basis	No reimbursement floor. Act 77 expands PBM registration, transparency, network-adequacy, and anti-steering rules for fully-insured plans and directed the Insurance Department to study a NADAC-plus-dispensing-fee model — but did not enact a floor. MAC transparency and appeals sit in the existing Pharmacy Audit Integrity and Transparency Act.
Professional dispensing fee	Not specified in statute (a $10.49 figure appeared only as a parameter of the mandated study)
Appeal route	Under the Pharmacy Audit Integrity and Transparency Act (40 P.S. ch. 45)

Pennsylvania’s Act 77 of 2024 strengthens PBM oversight for fully-insured commercial plans — registration, transparency, network adequacy, and anti-steering — but it does not create a reimbursement floor. Reimbursement protection remains the MAC transparency and appeals regime in the Pharmacy Audit Integrity and Transparency Act.

The much-cited “NADAC + $10.49” figure comes from a study the Act directed the Insurance Department to perform, not from an enacted requirement. The Department’s own materials are explicit that this was an evaluation, not a mandate.

Sources

Pennsylvania Insurance Department — Act 77 Pharmacy Benefit Reform Act Primary source
Pennsylvania Insurance Department — Act 77 impact study (NADAC + $10.49 evaluated, not mandated) Primary source

Back to the tracker