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

Virginia: what the PBM reimbursement law requires

Virginia requires MAC transparency with a 14-day appeal and bars a PBM from paying a pharmacy less than it pays an affiliate — but only for fully-insured commercial plans, and with no reimbursement floor tied to drug cost.

Status Partially enacted
Law Va. Code § 38.2-3407.15:3 (MAC) and § 38.2-3467 (PBM conduct)
Effective date MAC provisions since January 1, 2016; PBM conduct rules since 2020
Reimbursement basis No reimbursement floor tied to drug cost. A PBM may not reimburse a pharmacy less than it pays a PBM affiliate for the same pharmacist services, per unit (anti-self-dealing parity), and must keep MAC pricing transparent with a MAC appeal. ERISA self-funded plans, Medicaid, and Medicare Part D are excluded.
Professional dispensing fee Not specified in statute
Appeal route Pharmacy may dispute a MAC within 14 days of initial claim adjudication; the carrier resolves within 14 days, with a reason and NDC/wholesaler information on denial

Virginia regulates PBMs through MAC transparency and anti-self-dealing parity rather than a drug-cost floor, and only for fully-insured commercial plans. A pharmacy may dispute a MAC within 14 days of adjudication, and a PBM may not pay a pharmacy less than it pays its own affiliate for the same pharmacist services.

These protections expressly exclude self-funded ERISA plans, Medicaid, and Medicare Part D, and they do not tie reimbursement to NADAC or acquisition cost. A 2026 law tightens other PBM conduct but still adds no commercial floor.

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