PBM Annual Reporting Requirements

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

To be announced closer to April 1, 2026. All questions should be submitted to the Insurance Department by emailing ra-in-pbm@pa.gov.

• Pharmacy Benefit Manager Network Adequacy Report – Part 1: PBM Network Data
• Pharmacy Benefit Manager Network Adequacy Report – Part 2: PBM Network Narrative

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.

To be announced closer to July 1, 2026. All questions should be submitted to the Insurance Department by emailing ra-in-pbm@pa.gov. All submissions are privileged and will be given confidential treatment. 

• Pharmacy Benefit Manager Annual Transparency Report Template
• Pharmacy Benefit Manager Annual Transparency Data Template