MI| Bulletin 2025-02-INS outlines the requirements for pharmacy benefit managers (PBMs) operating in Michigan under the Pharmacy Benefit Manager Licensure and Regulation Act, which took effect on January 1, 2024. The bulletin mandates that PBMs must submit their first transparency report for the calendar year 2024 by April 1, 2025, and annually thereafter, unless more frequent submissions are required by the DIFS Director. Failure to submit timely reports may result in administrative action.
Key points:
- DIFS has created the FIS 2396 PBM Transparency Report form to ensure consistency and facilitate timely reporting. This form should be used by PBMs to report aggregate wholesale acquisition costs, rebates, and fees for drug therapeutic categories.
- Information submitted in the transparency report is exempt from disclosure under the Freedom of Information Act, except as needed for legislative reporting. PBMs can find additional information about licensure and regulatory requirements at www.michigan.gov/difs/pbm.