Requirements for 2026 Licensure of Pharmacy Benefit Managers
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Establishes Massachusetts Division of Insurance requirements and application process for initial Pharmacy Benefit Manager (PBM) licensure effective for operation on and after January 1, 2026; affects any person, business, or entity seeking to operate as a PBM in Massachusetts.
Establishment of mandatory licensure for PBMs operating in Massachusetts effective January 1, 2026 under M.G.L. c. 176Y.
Specification of required application contents (organizational, operational, financial, ownership disclosures, insurance, and service plans) for an initial one-year license for 2026.
Initial and subsequent nonrefundable filing fees defined: $8,334 for initial one-year term and $25,000 for subsequent three-year term.
Application submission timeline and MOVEit electronic submission process, with deadline October 15, 2025.
Initial Application Requirements
Actions Required of Applicants
Do not operate as a PBM until license issued
Applicants that have not been issued a PBM license are prohibited from conducting the activities of a PBM in Massachusetts until the Division issues a license; applicants may not operate in the Commonwealth until a license is issued and late or incomplete submissions may lead to denial or delayed licensure.
Initiate MOVEit access and submit application electronically
Submit the completed application electronically via the Commonwealth's MOVEit system. Initiate MOVEit access configuration by emailing DOI.PBM@mass.gov with the name, email, phone number, and company/affiliation of the individual who will submit the application; allow multiple business days for MOVEit configuration and contact DOI.PBM@mass.gov promptly to avoid delays. All materials must be submitted by October 15, 2025.
- Email DOI.PBM@mass.gov to initiate MOVEit access and provide: Name; Email address; Phone number; Company/Affiliation.
- Allow sufficient time for MOVEit configuration (can take multiple business days).
- Deadline for all application materials and fee: October 15, 2025.
Filing fee must be paid and received before license issuance
Send the required nonrefundable filing fee by check or money order payable to 'Commonwealth of Massachusetts' and ensure the Division has received payment before a PBM license will be issued.
- Initial one‑year filing fee: $8,334; subsequent three‑year filing fee: $25,000.
- Mail payment by certified mail to: Division of Insurance, Attn: Company Licensing, One Federal Street, 7th Floor, Boston, MA 02110.
- Reference 'PBM Application Filing Fee' and the Applicant's name on the payment.
Key Definitions
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