State Pharmacy Benefit Management Reform in 2025
States enacted significant pharmacy benefit manager reforms in 2025, including Arkansas's historic pharmacy ownership ban, Massachusetts's comprehensive licensing requirements, and Colorado/California's compensation delinking laws.
States Expand Genomic Testing Coverage (Rapid Whole Genome Sequencing and Biomarker Testing)
Seventeen state Medicaid programs now cover rapid whole genome sequencing for critically ill children, with Minnesota, North Carolina, Oklahoma, and Tennessee extending coverage to patients under 21 in pediatric critical care. Sixteen states mandate biomarker testing coverage for cancer-risk beneficiaries. Maryland and Illinois enacted legislation prohibiting genetic discrimination in life insurance policies.
Health Policy Rollup: State Action We Watched in September and October 2025
California signed SB 306 requiring health plans to report prior authorization denial rates and eliminate requirements for services with 90% approval rates by 2028. Kansas recommended 340B transparency legislation following committee hearings. New Mexico allocated $50 million for rural healthcare and $17 million for Marketplace subsidies during special session. West Coast states issued coordinated winter vaccination recommendations.
States Prepare Applications for Rural Health Transformation Program
CMS released guidance for states applying to the Rural Health Transformation Program's $50 billion in federal funding distributed between FY2026-FY2030. States like Mississippi, Oklahoma, North Dakota, and Washington are conducting stakeholder surveys and forming committees to develop applications focusing on workforce development, technology infrastructure, and healthcare access improvements. Applications are due November 5, 2025, with approvals by December 31.
Colorado Adopts Nation’s First Upper Payment Limit for a Prescription Drug
Colorado's Prescription Drug Affordability Board finalized the first-ever upper payment limit for a prescription drug, capping Enbrel at $600 per 50mg/mL effective January 2027. The biologic treats autoimmune diseases and was deemed unaffordable in February 2024. Colorado joins Maryland, Washington, and Minnesota as states with price-setting authority, while Maryland considers limits for diabetes drugs Jardiance and Farxiga.
States Diverge on Vaccine Policy as Federal Guidance Shifts
The FDA recently limited COVID-19 vaccine eligibility to adults 65+ and younger people with qualifying conditions, while disbanding the CDC's advisory committee. States are responding differently: Massachusetts, Nevada, and New Mexico restrict pharmacy access to FDA guidelines only, while Pennsylvania and New York expanded access through state orders. California, Oregon, Washington, and Hawaii formed the West Coast Health Alliance for independent guidance. Florida plans eliminating all vaccine mandates, including childhood school requirements.
Hospital Facility Fee Legislation Gains Momentum Across 11 States
Eleven states considered facility fee legislation in 2025 as hospital ownership of outpatient settings expands. These charges cover costs beyond provider billing but have drawn criticism from insurers as unfair markups for consumers in non-hospital settings. Key legislative trends include requiring health systems to report facility fee data to state agencies, prohibiting or limiting certain facility fees, and establishing consumer notice requirements. The push reflects growing state concern over billing practices as hospital systems increasingly acquire physician practices and outpatient facilities.
State Medical Debt Laws Expand Despite Federal Court Setback
In 2025, states enacted 14 medical debt reform laws across 10 states after a Texas court struck down Biden's CFPB rule banning medical debt from credit reports. Maryland passed the most comprehensive package, while Delaware, Maine, Oregon, Rhode Island, Vermont, and Washington prohibited credit reporting. Over 123 bills were introduced across 38 states addressing collections, interest rates, and reporting practices.
How States Continue Shaping Reproductive Health Policy, Three Years Post-Dobbs
Three years after Dobbs overturned Roe v. Wade, reproductive health policy continues evolving rapidly in 2025. Missouri successfully placed a ballot measure to overturn voter-enacted abortion protections on the 2026 ballot, while Montana failed to achieve the two-thirds vote needed for fetal personhood. Interstate legal battles intensified as Texas and Louisiana attorneys general pursue cases against a New York doctor prescribing abortion pills across state lines. Emergency abortion policies split along partisan lines, with red states clarifying ban exceptions while blue states codify EMTALA protections into state law.
New Jersey and Oregon Target Behavioral Health Reform and Patient Protections
Oregon enacted comprehensive behavioral health reform legislation, with Governor Kotek signing bills that allocate $65.7 million for provider capacity, establish workforce recruitment programs, broaden civil commitment standards, and create youth substance use prevention strategies. Meanwhile, New Jersey focused on protecting patients from predatory practices by criminalizing patient brokering as a third-degree offense with mandatory $50,000 penalties and prohibiting deceptive marketing by addiction treatment providers. Both states' approaches reflect growing concerns about behavioral health access and quality care standards.
State Medicaid Programs Face Huge Federal Funding Cut
President Trump signed the One Big Beautiful Bill Act on July 4, 2025, cutting federal Medicaid spending by $1.02 trillion over ten years. The legislation imposes work requirements, freezes provider tax rates, caps state-directed payments, and requires six-month eligibility redeterminations for expansion states. Most significant budget impacts won't hit states until 2028.
State Behavioral Health Legislative Trends in 2025: Parity, Workforce Shortages, and More
Twenty-nine states enacted 75 mental health bills in 2025, driven by federal parity requirements and workforce shortages. Georgia, Alaska, Oklahoma, and Washington passed parity compliance measures responding to federal MHPAEA implementation. New Mexico prioritized behavioral health through dedicated trust funds and eliminated cost-sharing. Texas expanded loan repayment programs up to $180,000 for psychiatrists, while Maryland established statewide 9-8-8 crisis systems.
Health Policy Rollup: State Action We’re Watching in August 2025
Alaska enacted comprehensive prior authorization reforms establishing determination timelines and 12-month approvals for chronic conditions. Illinois prohibited AI use in mental health decision-making to protect consumers and providers. Maryland's PDAB determined diabetes drugs Farxiga and Jardiance create affordability challenges and may consider upper payment limits. Massachusetts strengthened shield law protections for physicians providing abortion and gender-affirming care, preventing data disclosure and blocking cooperation with federal investigations. New Hampshire set out-of-network ambulance reimbursement at 325% of Medicare for two years.
HHS Cuts $500 Million in mRNA Vaccine Research Funding
Secretary Robert F. Kennedy Jr. canceled approximately $500 million in federal mRNA vaccine research funding, halting 22 active projects amid safety and necessity concerns from supporters. Scientists and public health leaders warn the cuts will weaken pandemic preparedness and push research talent overseas. The federal action follows state legislative trends in Kentucky, Iowa, Idaho, and Florida targeting mRNA technology restrictions, with Florida enacting protections against mRNA vaccination discrimination. Additional similar state legislation is expected in 2026 as the policy debate continues.
Prior Authorization Reform Gains Momentum in States
States pursued multiple approaches to reduce prior authorization barriers in 2025, with gold card programs leading reform efforts. Arkansas, Texas, and West Virginia amended existing gold card legislation, while Iowa's pilot program was removed. Indiana and Montana established 24-48 hour review timeframes and coverage continuity requirements. Maryland restricted AI use in determinations, requiring patient-specific data and human physician oversight for adverse decisions.
Pharmacy Benefit Manager Reform: How States Are Changing PBM Operations
States are pursuing extensive pharmacy benefit manager reforms beyond traditional gag clause prohibitions and reporting requirements. Key strategies include delinking PBM compensation from drug prices (Colorado), requiring rebate pass-throughs to consumers (Utah), establishing fiduciary duties to health carriers (North Carolina), and prohibiting PBM pharmacy ownership (Arkansas). Colorado's delinking reform takes effect January 2027, while Arkansas faces legal challenges over its pharmacy ownership ban. These comprehensive approaches represent escalating state efforts to curb PBM practices.
Governors Sign PBM Reform as Legal Challenges Mount
Four governors signed significant PBM reform legislation in recent weeks, with North Carolina, Connecticut, Illinois, and Louisiana enacting comprehensive measures including rebate pass-through requirements, spread pricing prohibitions, and enhanced transparency reporting. However, legal challenges are mounting against state PBM laws. Arkansas faces three lawsuits over its pharmacy ownership ban, Iowa's reform law was temporarily blocked by federal court, and the Supreme Court declined to hear Oklahoma's case, leaving a restrictive appellate ruling in place that could impact future state PBM regulation.
Budgets Dictate Healthcare Headlines as States Adjourn
States incorporated significant healthcare reforms into budget bills as sessions concluded and the new fiscal year began July 1st. California's $321 billion budget freezes Medicaid enrollment for undocumented adults starting 2026, while Minnesota eliminated coverage for approximately 15,000 undocumented adults. Florida boosted Medicaid rates for long-term care facilities by $286 million, Ohio established automatic Medicaid expansion termination if federal match drops below 90%, and Wisconsin raised hospital provider taxes to generate $1.5 billion in additional Medicaid funding.
Health Policy Rollup: State Action We’re Watching in July 2025
Connecticut Governor Lamont signed comprehensive healthcare reform including mental health parity reporting and step therapy prohibitions. Iowa and Montana submitted federal waivers for Medicaid work requirements, seeking 100 and 80 monthly hours respectively. Oklahoma's Governor Stitt issued an executive order implementing "Make America Healthy Again" initiatives, including SNAP waivers to exclude soft drinks and ending public water fluoridation endorsements. Maine's legislature passed PDAB expansion legislation, but Governor Mills postponed her decision until January 2026.
End-of-Session Roundup: States Pass Major Healthcare Legislation in 2025
Legislative sessions concluded across most states this past month, with significant healthcare legislation passing nationwide. Texas enacted bills expanding healthcare cost disclosure, modifying prior authorization, and clarifying abortion exceptions. Oklahoma's legislature overrode gubernatorial vetoes on 340B, scope of practice, and breast cancer imaging coverage. Connecticut's budget included provisions creating CDC/FDA advisory committees, codifying fluoride requirements, and limiting generic drug price increases to inflation rates.