MA| The Massachusetts Division of Insurance Bulletin 2025-04, establishes the licensing requirements for Pharmacy Benefit Managers (PBMs) operating in Massachusetts for the 2026 calendar year, pursuant to Chapter 342 of the Acts of 2024 and M.G.L. c. 176Y. All PBMs must obtain a license from the Division of Insurance by January 1, 2026, to legally conduct business in the Commonwealth.
Key Points:
- All PBMs must submit a detailed licensure application—including organizational, operational, and financial information—by October 15, 2025; failure to do so prevents legal operation as a PBM in Massachusetts starting January 1, 2026.
- The initial license is valid for one year (2026), requires a non-refundable filing fee of $8,334, and subsequent three-year licenses cost $25,000, with submission through Massachusetts’ secure MOVEit system and specific access configuration steps.
- Applicants must promptly report any material changes to the submitted information within 30 days and include comprehensive documentation such as biographical affidavits, audited financial statements, and insurance certificates as outlined in the Bulletin.
