Simone Colgan Dunlap, Partner

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New York State Department of Financial Services Reporting Requirements for Pharmacy Benefit Managers

Health & Life Sciences Simone Colgan Dunlap, John E. Hintz, Katie Lavigne

Effective August 31, 2022, the New York State Department of Financial Services adopted regulations further detailing registration and reporting requirements for pharmacy benefit managers (available here). These regulations provide the information required from pharmacy benefit managers when registering, including organizational documents and bylaws, or other documentation regulating the entity's internal affairs, and a copy of the entity's standard, generic contract template, including the provider manual or other items incorporated by reference that the entity uses when contracting with pharmacists, pharmacies, or pharmacy service administration organizations in New York. For pharmacy benefit managers already registered in New York, the first annual report must be filed no later than July 1, 2022. Additional instructions for the annual report can be found on the Department of Financial Services’ pharmacy benefit manager website.

Currently, New York requires every pharmacy benefit manager performing pharmacy benefit management services to register with the New York State Department of Financial Services from June 1, 2022 through December 31, 2023 (see N.Y. Ins. Law §§ 2901 et. seq. and N.Y. Pub. Health Law § 280-a). On or after January 1, 2024, a pharmacy benefit manager must obtain a license with the New York State Department of Financial Services.

For more information, please contact your Quarles & Brady Health Law attorney or:

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