PBM Reimbursement(s) Below NADAC Amounts
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This bulletin governs Arkansas-licensed pharmacy benefits managers (PBMs), requiring reimbursements to pharmacies for ingredient drug products to meet or exceed the current NADAC at time of claim submission and announcing penalties for violations effective after June 30, 2024.
AID will begin applying penalties against PBMs reimbursing below current NADAC amounts on a per-prescription basis on and after June 30, 2024.
PBMs are reminded that reimbursing pharmacies less than the current NADAC at time of claim submission is a violation of Ark. Code Ann. § 23-92-506(b)(5).
Reimbursement and Enforcement Criteria
NADAC reimbursement and enforcement criteria
Requirements and enforcement criteria for PBM reimbursements to pharmacies in Arkansas:
Pricing References and Reimbursement Minimums
| NADAC | National Average Drug Acquisition Cost — reimbursement floor for ingredient drug product component when available |
| WAC | Wholesale Acquisition Cost — fallback reimbursement floor when NADAC unavailable |
Required Actions and Enforcement Dates for PBMs
Enforcement start date
AID will begin applying penalties against PBMs violating NADAC reimbursement minimums on a per-prescription basis on and after June 30, 2024.
Reimbursement minimum requirement
PBMs must reimburse pharmacies for the ingredient drug product component at no less than the current NADAC at the time of claim submission; if NADAC is unavailable, reimburse at no less than WAC (Wholesale Acquisition Cost).
Penalty authority
The Commissioner may impose penalties of up to $5,000 per violation under Ark. Code Ann. § 23-92-508(c) for violations of the NADAC reimbursement provisions.
Key Definitions
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