Healthcare policy groups including FARB, NAIC, NAMD, NASHP, and NCOIL serve as platforms for state policymakers to collaborate and shape emerging trends. In 2025, multiple organizations adopted model legislation on facility fees and site-neutral payments, with NCOIL passing its Prior Authorization Reform Model Act in November. Groups are now focusing on the Rural Health Transformation Program and 340B oversight for 2026.

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.

States enacted significant pharmacy benefit manager reforms in 2025, with Arkansas implementing the nation's first PBM-pharmacy ownership ban despite facing legal challenges. Massachusetts passed comprehensive licensing requirements, while Colorado and California adopted "delinking" laws prohibiting PBM compensation tied to drug prices. Utah mandated rebate pass-through mechanisms. These diverse approaches reflect growing bipartisan momentum toward curbing PBM practices affecting independent pharmacies and drug pricing transparency.

As federal vaccine recommendations become less consistent, states are increasingly asserting independent authority over immunization policies. Several states formed regional collaboratives for vaccine guidance and procurement in late 2025, while others enacted legislation replacing federal recommendations with state-based advisories. Conversely, some states like Florida are moving to eliminate school vaccine mandates and emphasize parental choice through regulatory changes.

Fifteen governors launched a public health alliance to improve emergency preparedness and coordination across state lines, while CMS announced all 50 states applied for the $50 billion Rural Health Transformation Program. California enacted major healthcare transparency and PBM oversight legislation, Colorado proposed significant Medicaid spending cuts, and Massachusetts advanced prior authorization reforms.

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 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.

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.

As legislative sessions wind down across the country, attention turns to the executive branch as governors make decisions on bills passed by the legislature. In the past month, various governors have taken action on significant healthcare legislation by signing, vetoing, or allowing bills to become law.

Legislation we’re watching this month, including Certificate of Need in Mississippi, facility fees in Oregon, Medicaid reform in Indiana, and more.

During the 2024 state legislative sessions, 33 bills were enacted in 20 states related to the regulation of pharmacy benefit managers (PBMs). States used a variety of tactics, including spread pricing prohibitions, 340B pharmacies, patient steering and affiliated pharmacies, and mandates for increased reporting of PBM activities.