As a result of the passage of Act 77, The Insurance Department (PID) announced a process for pharmacies to dispute a drug’s designation as a “specialty drug” by a PBM or insurer. PID also published a non-binding, non-exclusive list of “specialty drugs,” as well as guidance on how a pharmacy can request a review of a specialty drug designation. This process will be available in 2025 for drugs covered by large group policies issued after October 15, 2024, and by individual and small group policies issued on or after January 1, 2026. Beginning in 2026, PID will also release two annual reports, a Network Adequacy Report is due by April, and a Transparency report will be available by July. These reports will provide critical data on manufacturer rebates and pharmacy reimbursement rates to help identify areas for further action or reform.
NACDS strongly encourages members to review both the proposed list and the complaint process and share your comments with Jill McCormack. We intend to work with PID to help you build and revise the list and to encourage the most efficient process for our members to dispute designations.
PBMs and pharmacies can find more information on Act 77, including a schedule that outlines the Act’s full implementation dates, visit PID’s website. To submit a complaint, contact the PID’s Consumer Services Bureau online or at 1-877-881-6388.
For more information, contact NACDS’ Jill McCormack at 717-592-8977.