Welcome to The Legislative Dose, SlateRx’s regular briefing on the ever-evolving world of pharmacy benefits legislation. This brief report will provide insights and updates on policies, regulations, reforms, and trends shaping the pharmacy benefits space that impact plan sponsors and patients alike. Consider this a concise, reliable resource for staying informed and prepared in a shifting legislative landscape.
Recently Passed Legislation
Arkansas – Act 624 (House Bill 1150)
Signed: April 16, 2025
Summary: Prohibits PBMs and their affiliates from owning or operating retail or mail-order pharmacies in Arkansas. Beginning January 1, 2026, the Board of Pharmacy will revoke or refuse to renew any pharmacy license held by a PBM or its subsidiary. Limited exceptions exist for short-term permits covering rare or critical drugs, but these expire by September 1, 2027.
Status: Facing legal challenges from CVS and Express Scripts, and currently stayed via injunction.
What it could mean for your plan: For plans with members in Arkansas, PBM-owned pharmacies could be off limits. If the law takes effect January 1, 2026, any PBM or its subsidiary that owns or operates a retail or mail-order pharmacy in Arkansas would lose its state pharmacy license. Because the law is stayed pending legal challenges, plans can maintain the status quo for now. However, the injunction could be lifted quickly, so contingency planning is advisable.
Iowa – Senate File 383
Signed: June 11, 2025
Summary: Restricts PBMs from steering patients to preferred pharmacies, under-reimbursing pharmacies, or designating drugs as “specialty” to limit access. The law also sets specific contract requirements for PBMs, insurers, and employers.
Status: Opponents, including business groups, insurers, and employers, have filed a federal lawsuit challenging the law’s legality and constitutional grounds. Key provisions have been preliminarily enjoined for ERISA plans—any willing provider requirements, cost-sharing requirements, pharmacy steering prohibitions, and portions of the reporting and disclosure requirements.
What it could mean for your plan: For plans with members in Iowa, Senate File 383 would mean significant changes to how pharmacy networks and drug access are managed, though, like the Arkansas law, its future depends on the outcome of ongoing litigation. As written, PBMs could not require or heavily incentivize members to use a “preferred” pharmacy. Plans that currently drive Iowa members toward in-house mail-order, specialty, or retail partners would need to offer true choice among in-network pharmacies. While the case plays out, enforcement may be delayed, but plans should be ready to pivot if the law is upheld.
Recently Rejected Legislation:
Louisiana — Proposed PBM–Pharmacy Ownership Ban
A measure aiming to ban companies from owning both pharmacies and PBMs (targeting vertical integration) passed the Louisiana House with strong bipartisan support but failed in the Senate during the session’s final hours. Governor Landry has signaled a possible special session to revive a similar bill.
On the Horizon:
California – SB 41 (Pending)
Passed Senate: June 2, 2025
Next steps: Under consideration by the Assembly; not yet signed.
Summary: A sweeping PBM reform bill designed to increase transparency and reduce drug costs. Key provisions include:
- Mandatory PBM licensing through the Department of Insurance by 2027.
- Prohibits spread pricing starting in 2026, with voiding of past spread terms by 2029.
- Requires full pass-through of rebates and cost concessions.
- Sets reimbursement floors at NADAC or wholesale acquisition cost, plus dispensing fees.
- Enforcement includes civil penalties, public reporting, and non-discrimination protections for independent pharmacies.
Status: Faces strong industry opposition and the precedent of similar bills being vetoed in previous years.
What it could mean for your plan: Major contract overhauls may be required in order to comply if you have members in California. Plans will need to eliminate spread-pricing in agreements starting January 1, 2026, contracts must clearly pass rebates through to reduce patient costs, and cost-sharing structures may need rewriting to align with actual drug costs. Plans should start now on contract reviews, network adjustments, financial modeling, and reporting upgrades to ensure PBM partners comply with SB 41’s upcoming bans on spread pricing, rebate passthrough rules, cost-sharing reforms, and pharmacy access protections.
Our Take:
As the pace of legislative activity around PBMs accelerates, staying ahead of the curve is more important than ever. Laws can pass quickly, stall unexpectedly, or face immediate legal challenges that alter their impact. With significant proposals like California’s SB 41 still in play and other states signaling similar efforts, the pharmacy benefits space will remain dynamic in the months ahead.
SlateRx will continue to track these developments closely, distill their implications, and provide you with timely, actionable insights—so you can make informed decisions and stay prepared in an evolving regulatory environment.
