Alabama
The Department of Insurance (DOI) updated its PBM compliance website.
Updates include:
- Updated fax number (Please note the PBM Compliance Department has an updated fax number: 334-241-4110; the old fax number should no longer be operational.)
- Updated pharmacy complaint form (to remove patient PHI information)
- Reimbursement complaint spreadsheet template
- Best practices document
- Updated PBM actions page
- Links to PBM related laws and regulations
- Consumer complaint form and
- List of additional resources, including the National Association of Insurance Commissioners (NAIC), the Board of Pharmacy, stakeholder websites and Medicaid Average Acquisition Cost (AAC) reimbursement.
DOI will still accept the old complaint forms but would prefer pharmacies to move over to the new template in the upcoming weeks.
Also in Alabama, the Board of Pharmacy met last week and heard comments on its proposed rule for a Civil Penalty Schedule. This includes proposed fine ranges for violations by all license and permit holders. They voted to have an amended version published by next week and restart the public comment period. Be on the lookout for more information once the revised version is available. You can listen to the entire Board of Pharmacy meeting online.
For more information, contact NACDS’ Leigh Knotts at 803-243-7207.
California
The Department of Health Care Services posted the following on the Medi-Cal Rx Web Portal. Please note reminders and urgent messages below.
For more information, contact NACDS’ Sandra Guckian at 703-774-4801.
Colorado
NACDS testified in support of HB26-1336, a bill designed to expand access to pharmacy healthcare services for both Medicaid and commercial patients, at a House Health and Human Services Committee hearing on March 31. The bill was amended to allow children 5 years of age and older to receive test-and-treat services directly from pharmacies. Additionally, it permits pharmacy technicians, under pharmacist supervision, to perform final product verification and other technical, non-discretionary tasks.
Also in Colorado, SB26-032, a bill designed to expand access to pharmacy vaccine services by increasing pharmacists' authority to prescribe and administer vaccines and by providing liability protections for pharmacists, was signed into law by Gov. Jared Polis (D) on March 27.
For more information, contact NACDS’ Mary Staples at 817-442-1155.
Florida
Gov. Ron DeSantis (R) signed HB 697, which will take effect July 1. The legislation includes provisions related to the Ryan White Part B AIDS Drug Assistance Program (ADAP), providing bridge funding to maintain the program without changes through June 30. The law also prohibits PBMs from restricting a pharmacy or pharmacist from declining to dispense a drug when the reimbursement rate is below the actual acquisition cost. Additionally, it bars PBMs from reimbursing a pharmacy or pharmacist at a lower rate than they reimburse an affiliated pharmacy or pharmacist. Finally, the law states that the administrative appeal procedure must allow a pharmacy or pharmacist the option to submit a consolidated administrative appeal representing multiple adjudicated claims that share the same drug and day supply and have a date of service occurring within the same calendar month.
For more information, contact NACDS’ Leigh Knotts at 803-243-7207.
Idaho
The Board of Pharmacy posted minutes from its March 19 meeting.
For more information, contact NACDS’ Sandra Guckian at 703-774-4801.
Illinois
The Department of Healthcare and Family Services (HFS) Bureau of Professional and Ancillary Services (BPAS) occasionally receives requests from clinicians in the provider community for individual drug reviews. To ensure requests for reviews are fair, balanced and relevant to the Medicaid Preferred Drug List (PDL), the BPAS has established procedures for handling these requests. After the BPAS receives the request for a drug review, the BPAS pharmacy staff establish the appropriateness of the request. The review takes place over a three-month period, beginning from the date the drug review is requested. Reviews are evaluated both clinically and financially. A recommendation may be presented to the Drugs & Therapeutics (D&T) Advisory Board at the earliest opportunity.
For more information, contact NACDS’ Leigh Knotts at 803-243-7207.
Kansas
NACDS sent Gov. Laura Kelly (D) a letter urging her to sign the Consumer Prescription Protection and Accountability Act. SB 20, formerly SB 360, is a comprehensive PBM reform bill that clarifies auditing procedures, specifies reporting requirements and strengthens enforcement authority by enabling both compliance and financial examinations.
For more information, contact NACDS’ Mary Staples at 817-442-1155.
Missouri
SB 878, was amended and passed the Senate on March 23. The bill expands pharmacists’ scope authority for CLIA-waived tests and allows prescribing certain types of medical equipment. It also enhances the Board of Pharmacy’s authority to allow pharmacies to dispense medications during a declared emergency. In addition, it would allow the over-the-counter sale of ivermectin and hydroxychloroquine, with a warning label, once the FDA authorizes them for over-the-counter dispensing. The bill was sent to the House of Representatives for further action.
For more information, contact NACDS’ Mary Staples at 817-442-1155.
Nebraska
The Department of Health and Human Services announced a public hearing to receive comments on proposed changes to Title 471, Chapter 7 of the Nebraska Administrative Code (NAC) – Durable Medical Equipment, Prosthetics, Orthotics, and Medical Supplies (DMEPOS).
Authority for these regulations is found in Neb. Rev. Stat. § 81-3117(7) and § 68-908.
Interested persons may attend the hearing and provide verbal or written comments, or mail, fax or email written comments, no later than the day of the hearing to: DHHS Legal Services, PO Box 95026, Lincoln, NE 68509-5026, (402) 742-2382 (fax) or dhhs.regulations@nebraska.gov, respectively.
A copy of the proposed changes is available online at http://www.sos.ne.gov, or by contacting DHHS at the mailing address or email above, or by phone at (402) 471-8417. The fiscal impact statement for these proposed changes may be obtained at the office of the Secretary of State, Regulations Division, 1201 N Street, Suite 120, Lincoln, NE 68508, or by calling (402) 471-2385.
For more information, contact NACDS’ Sandra Guckian at 703-774-4801.
Ohio
Gov. Mike Dewine (R) signed HB 229, sponsored by Rep. Kelli Deeter (R), into law this week. The law establishes licensure for PBMs beginning in 2027; prohibits certain PBM practices; and allows the Department of Insurance to take disciplinary actions for violations, including fines and license suspension or revocation. Additionally, it requires PBMs to enter into written agreements and provide regular accounting of rebates, fees and other financial arrangements to plan sponsors and permits the Department to access PBM records and data.
For more information, contact NACDS’ Jill McCormack at 717-592-8977.
Oklahoma
On March 26, the Senate passed SB 2074 by a decisive 34-3 vote. This bill aims to establish a reimbursement rate floor of NADAC plus a dispensing fee that cannot be lower than the Medicaid fee-for-service rate. The legislation was reported to the House for further consideration.
For more information, contact NACDS’ Mary Staples at 817-442-1155.
Oregon
The Board of Pharmacy posted two current Board Member Opportunities:
- Public Board Member Position - Apply Now!
- Pharmacist Board Member Position - Apply Now!
Also in Oregon, the Prescription Drug Affordability Board (PDAB) posted its draft agenda for the April 15 meeting. Check the PDAB website for updates prior to the meeting. Register in advance.
For more information, contact NACDS’ Sandra Guckian at 703-774-4801.
Rhode Island
The Board of Pharmacy implemented a new Pharmacy Law Test effective April 1, as part of updates to pharmacy initial licensing and renewal requirements. The changes are being administered through the National Association of Boards of Pharmacy’s (NABP’s) Electronic Licensure Transfer Program.
For more information, contact NACDS’ Leigh Knotts at 803-243-7207.
South Carolina
Reminder: federal law requires all providers who order, refer or prescribe services or items for Medicaid members to be enrolled in that state's Medicaid program. This requirement applies to pharmacist administering drugs as allowed under state protocols and submitting their NPIs in the prescriber field. Please review the Medicaid Enrollment of Ordering, Referring and Prescribing (ORP) Providers and Collection of ORP Data bulletin (MB# 25-015) published on July 2, 2025, as background.
Also in South Carolina, NACDS met with the Department of Health and Human Services (SCDHHS) on March 11 and inquired about mass enrollment of pharmacists as Medicaid providers. The provider enrollment department has informed NACDS that, unfortunately, due to system limitations and CMS requirements, they are unable to offer a mass enrollment process to any provider type.
For more information, contact NACDS’ Leigh Knotts at 803-243-7207.
Tennessee
The Department of Health (TDH) continues to closely monitor respiratory syncytial virus (RSV) activity across the state. Recent emergency department data indicates that RSV activity remains elevated but has begun decreasing in Tennessee. Due to continued RSV activity in the state, pediatric providers and hospitals may continue to administer RSV immunizations to eligible infants through April 30. RSV immunizations remain available for ordering through TennIIS for the Vaccines for Children (VFC) program.
For more information, contact NACDS’ Leigh Knotts at 803-243-7207.
Texas
Lt. Gov. Dan Patrick (R) announced the Senate’s Interim charges, and Speaker Dustin Burrows laid out the House’s interim charges to prepare for the 2027 session.
For more information, contact NACDS’ Mary Staples at 817-442-1155.
Virginia
Gov. Abigail Spanberger (D) signed SB 669 (Chapter 36)/HB 830, a key initiative of her administration to address PBM structure in the commercial market. The law will require all health insurance carriers to use a pass-through pricing model. It also will prohibit a PBM from reversing and/or resubmitting a pharmacy claim without meeting certain requirements; reducing any pharmacy payment through effective rates; and retroactively denying or reducing a claim or aggregate of claims, except under certain circumstances. Additionally, it requires the State Corporation Commission to compile a report of its examination of PBM steering practices with recommendations to the General Assembly by December 1, 2027.
For more information, contact NACDS’ Jill McCormack at 717-592-8977.
Washington
The Board of Pharmacy has released updated self-inspection worksheets for 2025, covering various pharmacy practice settings and specialties. The comprehensive collection includes worksheets for general pharmacy operations, hospitals and HPACs, manufacturers, wholesalers and healthcare entities. Additional specialized addenda are available for long-term care facilities and various USP standards including nonsterile compounding (USP 795), sterile compounding (USP 797), hazardous drugs (USP 800) and radiopharmaceuticals (USP 825).
The Board also published a 2025 DSCSA self-inspection worksheet to help pharmacies comply with Drug Supply Chain Security Act (DSCSA) requirements.
For more information, contact NACDS’ Mary Staples at 817-442-1155.
West Virginia
Gov. Patrick Morrisey (R) signed HB 5430 , a bill that will further strengthen the state’s oversight of PBMs in both the commercial market and under the Public Employees Insurance Agency (PEIA). The law eliminates spread pricing; prohibits PBMs from using offshore group purchasing organizations (GPOs) to divert drug rebates; requires a 2026 pharmacy cost of dispensing study; and gives the Insurance Commissioner additional tools to regulate and oversee PEIA’s PBM.
For more information, contact NACDS’ Jill McCormack at 717-592-8977.
Alabama
The Department of Insurance (DOI) PBM Compliance Division has taken its first action against non-compliant PBMs. Actions have been filed against two entities: one taken in October against Drexi, Inc. for operating without a PBM license in the state, and one taken against Express Scripts, Inc. (ESI) this week for several violations, including charging of illegal fees; under payment of reimbursements; and failure and refusal to provide accounts, documents, records, files, information and matters relevant to the substance of complaints. The Department is enforcing Act 2025-36, also known as the Community Pharmacy Relief Act. Stay informed by visiting the DOI PBM Compliance Division page and the PBM Actions page.
Also in Alabama, the Board of Pharmacy proposed these rules for adoption. The required public comment period is now open, and we encourage all members to review them.
File written comments directly with the Board of Pharmacy as directed in the cover sheet for the rule. Deadlines for comments are provided on the rule filings. All written comments should be sent to Wpassmore@albop.com by the deadlines noted.
Finally in Alabama, the Board of Pharmacy scheduled several upcoming meetings for 2026, including April 15, May 20, June 17, July 15, August 19, September 16, October 14, November 18 and December 16. All meetings begin at 9:00 am CST/CDT unless otherwise noted.
For more information, contact NACDS’ Leigh Knotts at 803-243-7207.
California
Due to an overwhelming response, the Board of Pharmacy is opening more spots for those interested in attending a listening session on pharmacists provided consultation. Seeking to minimize barriers that exist for pharmacists providing consultation to patients, the Board is interested in hearing from licensed California pharmacists to gather information to assist in evaluating the Board's current consultation requirements. In addition, separate listening sessions will be scheduled so the Board can obtain input from patients and public participants.
Sessions will be conducted over WebEx. Please see the schedule of dates and times below. The Board respectfully requests individuals to register for ONLY ONE session to ensure other pharmacists have the same opportunity. If you previously registered for a session, please do not register for an additional session date.
We have increased the meeting capacity; however, space is still limited, and registration is required. To register, click on the link below for your preferred session:
Questions to be discussed during the listening session include:
- Do you believe patient consultation is needed for all prescriptions?
- How and where does the pharmacist provide patient consultation?
- Does the patient receive the medication prior to consultation?
- Should the pharmacy be required to document the consultation?
- Can technology assist in identifying, documenting, and providing patient consultation?
- What challenges or barriers exist making it difficult for the pharmacist to provide consultation?
- What is your vision of best practice for patient consultation?
- Are there opportunities for compensation for medication reviews and patient counseling?
- If you mail or deliver prescriptions to patients, how do you provide consultation?Do you believe the requirements should be different than face-to-face consultation?
The information provided will be considered during an upcoming Enforcement and Compounding Committee meeting.
Also in California, the Board of Pharmacy published its 2026 Lawbook.
Finally in California, NOTICE IS HEREBY GIVEN that the Board of Pharmacy (Board) has proposed modifications to the proposed regulatory text in section 1717.11 of article 2, division 17, title 16 of the California Code of Regulations, related to REMOTE PROCESSING. These regulations were originally noticed on January 9 and approved as modified by the Board at its March 18 meeting. Materials regarding this proposal can be found online or by requesting them from the contact person identified below.
Any person who wishes to comment on the proposed modifications may do so by submitting written comments between March 19 and April 3 to the following:
Contact Name: Debbie Damoth
Address: 2720 Gateway Oaks Drive, Suite 100 Sacramento, CA 95833
Fax number: (916) 574-8618
Email Address: PharmacyRulemaking@dca.ca.gov
Please note comments should be restricted to the most recent modifications made to the proposed regulations. The Board is not required to respond to comments on other aspects of the proposed regulations received in response to this notice.
Any comments previously submitted remain in the rulemaking file and will be responded to by the Board's staff as part of the Final Statement of Reasons. All written comments received by April 3 that pertain to these modifications, will be reviewed and responded to by the Board's staff as part of the compilation of the rulemaking file.
For more information, contact NACDS’ Sandra Guckian at 703-774-4801.
Colorado
SB26-032, a bill designed to expand access to pharmacy vaccine services by increasing pharmacists' authority to prescribe and administer vaccines and by providing liability protections for pharmacists, passed both legislative chambers and was sent to Gov. Jared Polis (D) to sign into law.
Also in Colorado, after months of stakeholder negotiations, HB 26-1336, the Increase Access to Pharmacy Services bill that NACDS supports, was filed last week. The bill would strengthen coverage requirements for the clinical services pharmacists provide within their scope of practice and expand pharmacy technicians' technical and nondiscretionary tasks that do not require a pharmacist's expertise and professional judgement. The bill also includes provisions that expand pharmacists' scope of practice to provide test & treat services for families with children 12 years of age and younger. A hearing is scheduled in the House Health Care and Health Insurance Committee on March 31.
For more information, contact NACDS’ Mary Staples at 817-442-1155.
Georgia
The Board of Pharmacy published a Notice of Intent to Adopt, Amend, or Repeal Rule 480-10A-.08 Notification to Patients, and Notice of Public Hearing on March 3. The Board also issued a Notice to Treatment Providers regarding Board Policy #9 on February 26.
Additionally, the Board posted a consumer alert about reports of scammers impersonating Board and Georgia Drugs and Narcotics Agency (GDNA) staff on March 4.
For more information, contact NACDS’ Leigh Knotts at 803-243-7207.
Illinois
The Department of Financial and Professional Regulation released the Compliance Capsule Spring 2026 newsletter, providing regulatory updates and compliance information for licensed professionals, including pharmacists.
For more information, contact NACDS’ Leigh Knotts at 803-243-7207.
Kansas
The Consumer Prescription Protection and Accountability Act, supported by NACDS and the Kansas Pharmacy Association, has been approved by both legislative chambers and was sent to Gov. Laura Kelly (D) for signature. SB 360 is a comprehensive PBM reform bill that clarifies auditing procedures, specifies reporting requirements and strengthens enforcement authority by enabling both compliance and financial examinations.
Also in Kansas, the Board of Pharmacy issued the March 2026 newsletter.
For more information, contact NACDS’ Mary Staples at 817-442-1155.