Virginia's Senate passed legislation to establish a Prescription Drug Affordability Board with upper payment limit authority, with similar House legislation pending under new Governor Abigail Spanberger. Four states currently have PDABs with UPL authority. Colorado became the first to set a UPL in October, effective January 2027, using Medicare's maximum fair price as the benchmark, though legal challenges remain ongoing.

Congress passed comprehensive PBM reforms requiring 100% rebate pass-through to ERISA plans, detailed disclosure requirements, and Medicare Part D compensation limits to bona fide service fees. California and Colorado already adopted delinking practices, while New Jersey and Virginia introduced similar legislation. Ten states have introduced rebate pass-through bills, with federal transparency standards potentially becoming state-level requirements.

The National Council of Insurance Legislators adopted the Prior Authorization Reform Model Act and advanced artificial intelligence oversight policies at its Atlanta annual meeting. The Health Insurance Committee addressed charity care screening requirements and medical debt protections, while the Financial Services Committee continued developing AI governance standards requiring human professionals to make claim denial decisions. Legislators discussed expiring ACA tax credits' impact on market stability with state insurance commissioners.