NJ| New Jersey DOBI Bulletin No. 26-04 supplements Bulletin No. 24-18 and gives Pharmacy Benefits Managers (PBMs) and Pharmacy Services Administrative Organizations (PSAOs) updated guidance on licensure/registration deadlines, financial statement flexibility, and how submitted information will be treated for public disclosure under P.L. 2023, c. 107.
Key Points:
- Confidentiality of submitted information: The bulletin classifies application data into three tiers — public (e.g., legal/DBA name, address, license status, FEIN, aggregate non-identifying financials), confidential (e.g., all materials while pending, ownership charts, contracts and fee schedules, audited statements, spread-pricing/rebate specifics, counterparty lists), and disclosable-with-redaction (e.g., biographical affidavits, mixed narrative responses, and enforcement-action lists once personal or proprietary details are removed).
- Licensure & registration deadline: PBMs must be licensed and PSAOs registered to operate in NJ, with all applications filed electronically through NIPR’s licensing center. PBMs without a complete application on file should submit by July 31, 2026 to avoid a lapse; interim authorization for those with a pending Notification of Organized Delivery System application cannot extend beyond December 31, 2026. Approved licenses/registrations are valid for three years, and denials can be appealed via hearing request within 30 days.
- Audited financial statements: While calendar-year audited statements are required, the Department will now accept fiscal-year statements, and until regulations are finalized, will also consider a parent company’s consolidated audited report (with the PBM/PSAO broken out on a schedule) as well as certified financial reports that may lack a formal audit opinion.