State Tracker Updated June 15, 2026

Wisconsin: what the PBM reimbursement law requires

Wisconsin requires PBMs to keep MAC pricing current and to provide a MAC appeal, but it sets no reimbursement floor and no commercial dispensing fee. NADAC-plus floor bills did not pass.

Status	Partially enacted
Law	Wis. Stat. § 632.865 (2021 Wisconsin Act 9)
Effective date	January 1, 2022
Reimbursement basis	No reimbursement floor. PBMs must update MAC pricing at least every 7 business days, give pharmacies a way to review updates, and provide a MAC appeal; on a successful appeal the PBM must identify an NDC available at or below MAC and adjust pricing. NADAC-plus floor bills (2024 and 2025) did not pass.
Professional dispensing fee	Not specified in statute
Appeal route	MAC appeal investigated and resolved within 21 days; if upheld, the pricing adjustment is made no later than one day after the determination and applied to similarly situated pharmacies

Wisconsin’s PBM law (Wis. Stat. § 632.865, from 2021 Act 9, effective January 1, 2022) is a MAC transparency-and-appeals regime. PBMs must update MAC pricing at least every seven business days and resolve a MAC appeal within 21 days, with the adjustment applied to similarly situated pharmacies if the appeal succeeds.

Bills that would have added a NADAC-plus-dispensing-fee floor (SB 737/AB 773 in 2024 and AB 173 in 2025) both failed to pass, so the in-force law sets no reimbursement floor and no commercial dispensing fee.

Sources

Wis. Stat. § 632.865 — Wisconsin Legislature (codified) Primary source
2021 Wisconsin Act 9 (enacting act) Primary source

Back to the tracker