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

Vermont: what the PBM reimbursement law requires

Vermont requires MAC transparency, a 10-day MAC appeal, an anti-self-dealing parity rule, and a spread-pricing ban — but it does not tie pharmacy reimbursement to NADAC or acquisition cost.

Status Partially enacted
Law 18 V.S.A. § 3631 (Act 127, 2024)
Effective date July 1, 2024
Reimbursement basis No reimbursement floor tied to drug cost. A PBM may not reimburse an in-state pharmacy less than it reimburses a PBM affiliate for the same pharmacist services (anti-self-dealing parity), must keep MAC pricing transparent (updated at least every 7 calendar days), and may not use spread pricing.
Professional dispensing fee Not specified in statute
Appeal route Pharmacy files within 10 calendar days of claim adjudication; PBM responds within 10 calendar days; if upheld, the PBM updates the MAC within 30 business days and permits reverse-and-rebill

Vermont’s PBM law (18 V.S.A. § 3631, from Act 127 of 2024, effective July 1, 2024) combines MAC transparency, a MAC appeal, anti-self-dealing parity, and a spread-pricing ban — but stops short of a drug-cost floor. A PBM may not pay an in-state pharmacy less than it pays its own affiliate for the same pharmacist services.

Pharmacies can appeal a MAC within 10 calendar days of adjudication, with a 10-day response window and a MAC update if the appeal succeeds. None of these provisions guarantee reimbursement at or above NADAC or acquisition cost.

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