Third Party Administrator (TPA) Licensing and Compliance Developments - January 2020

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In response to calls for greater transparency in the prescription drug industry, 2019 continued a nationwide trend of increased state licensing and regulation of pharmacy benefit managers (“PBMs”). In the last year, laws requiring PBMs to obtain PBM or Third Party Administrator (“TPA”) licenses/registrations from state regulators were passed or became effective in at least fourteen states. In addition to the new licensing requirements, numerous states also adopted requirements regulating other aspects of PBM operations.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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