Annual Reporting Requirements
Network Adequacy Report – Due April 1 Annually
Beginning April 1, 2026, and annually thereafter, Section 7 of Act 77 requires each registered PBM to submit to the Insurance Department a network adequacy report.
The PBM Network Adequacy Report is comprised of two parts:
- Part 1 is an excel template needed to capture data and details about the PBM Network.
- Part 2 is a word document needed to collect more narrative details, the PBM Network Narrative.
Submission Instructions
- Part 1: PBM Network Data files for analysis will be uploaded to a secure website. To gain access to this secure website, please email ra-in-pbm@pa.gov.
- Part 2: PBM Network Narrative file may be submitted to ra-in-pbm@pa.gov using the subject line: [COMPANY] PBM Network Narrative
Report Templates
Transparency Report – Due July 1 Annually
Beginning July 1, 2026, and annually thereafter, Section 7 of Act 77 requires each registered PBM to submit to the Insurance Department a transparency report. The transparency report contains data for each health insurer client in the Commonwealth regarding rebates received, administrative fees received, retained rebates, and data regarding reimbursements of affiliated entities.
Submission Instructions
Both the completed Transparency Report Template and the Transparency Data Template should be submitted via email to ra-in-pbm@pa.gov using the subject line: Transparency Report
All submissions are privileged and will be given confidential treatment. Please submit questions to the Insurance Department by emailing ra-in-pbm@pa.gov.
Report Templates
FAQs
Frequently asked questions about Network Adequacy and Transparency Reporting are listed below. If you need further assistance, please email ra-in-pbm@pa.gov.
Yes. Each registered pharmacy benefit manager (PBM) acting on behalf of a health insurer or health benefit plan as defined by Act 77 is responsible for complying with Act 77, including the reporting requirements.
If a PBM takes the position that it is exempt from, or has no information responsive to, one or more of the reporting requirements in Act 77, the Department expects that the PBM will provide a letter on company letterhead, signed by an authorized representative, explaining its position as to those reporting requirements. The Department also expects that the PBM will report as required for all other reporting requirements.
Each registered pharmacy benefit manager (PBM) acting on behalf of a health insurer or health benefit plan as defined by Act 77 is responsible for complying with Act 77, including the reporting requirements. As set forth in Act 77, except for the registration provisions in Chapter 5 of the Act, “this act shall not apply to a self-insured health benefit plan subject to ERISA or exempted from ERISA under section 4(b) of ERISA.”
If a PBM takes the position that it is exempt from, or has no information responsive to, one or more of the reporting requirements in Act 77, the Department expects that the PBM will provide a letter on company letterhead, signed by an authorized representative, explaining its position as to those reporting requirements. The Department also expects that the PBM will report as required for all other reporting requirements.
Each registered pharmacy benefit manager (PBM) acting on behalf of a health insurer or health benefit plan as defined by Act 77 is responsible for complying with Act 77, including the reporting requirements.
A PSAO should evaluate whether it may be a PBM under Act 77. If a PSAO performs pharmacy benefits management functions, it must be registered as a pharmacy benefit manager with the Department.
Each registered pharmacy benefit manager (PBM) acting on behalf of a health insurer or health benefit plan as defined by Act 77 is responsible for complying with Act 77, including the reporting requirements. The definitions of health insurer and health benefit plan do not encompass government program coverage under Medicaid, CHIP, or Medicare.
If a PBM takes the position that it is exempt from, or has no information responsive to, one or more of the reporting requirements in Act 77, the Department expects that the PBM will provide a letter on company letterhead, signed by an authorized representative, explaining its position as to those reporting requirements. The Department also expects that the PBM will report as required for all other reporting requirements
Yes, a PBM must submit one PBM Network Data Template for each network that it uses on behalf of one or more health insurers or health benefit plans as defined by Act 77. For each PBM Network Data Template submitted, a corresponding PBM Network Narrative must be submitted.
Each registered pharmacy benefit manager (PBM) in Pennsylvania is responsible for complying with Act 77, including the reporting requirements.
If a PBM takes the position that it is exempt from, or has no information responsive to, one or more of the reporting requirements in Act 77, the Department expects that the PBM will provide a letter on company letterhead, signed by an authorized representative, explaining its position as to those reporting requirements. The Department also expects that the PBM will report as required for all other reporting requirements.
“Pharmacy insurance tier” refers to the tier of the pharmacy within the network and the cost sharing responsibilities of members using different pharmacies, not the drug pricing differentiations between generic, brand, and specialty drugs.