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​​​​​​​​​​​​​​​Pharmacy Benefit Reform Act

Governor Shapiro signed House Bill 1993 into law on July 17, 2024, as Act 77 of 2024, the Pharmacy Benefit Reform Act.  Act 77 expands the Insurance Department's regulatory authority over Pharmacy Benefit Managers (PBMs), changes the registration process for PBMs and Auditing Entities, and introduces a new registration requirement for Pharmacy Services Administrative Organizations (PSAOs).

Important Dates & Implementation Schedule

Consumers, PBMs, and Pharmacies can find key dates and information on the implementation of Act 77.​

 Accordion



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​For Pharmacies:

​For PBMs:

​For Everyone:​​

 Content Editor


Full Implementation Schedule


​​Operative Provision
​Effective/Due Date & Next Steps
​​Specialty Drug Referral Process Guidance
​Guidance will be published on the Department’s website and in the PA Bulletin on or before January 13, 2025.
​​Contract Provisions of Section 601
(re:  contracts between PBMs conducting business on behalf of a health insurer client and Pharmacies)
​Apply to provisions of contracts issued, renewed, or amended after October 15, 2024, applicable to health insurer clients of the PBM.
​​PSAO Registration
Online registration is available.  Visit the Pharmacy Benefit Registration page for more information​.​​​​
​​PSAO Change of Control Reporting
​Form for change of control reporting to be posted to the Department’s website in advance of the November 14, 2024, effective date.
​​Increased Fee for PBMs and Auditing Entities
Online registration and renewal, with the increased fee, will begin on November 14, 2024. Visit the Pharmacy Benefit Registration page for more information​.​​​​
​​Study on Spread Pricing and Dispending Fees
​The Department will begin the process of conducting this study after the effective date of this provision (November 14, 2024).
​​Patient Steering/Clawbacks/
Network Adequacy Standards
These requirements will apply to contracts for which rates/forms are approved on or after October 15, 2024, as follows
    • Individual policies – either purchased through Pennie® or purchased directly from an insurance company - will include the Act 77 protections beginning January 2026. 
    • Many large employer group (more than 50 employees) fully-funded health benefit plans will include the Act 77 protections by mid-2025. 
    • Most small employer group (2-50 employees) fully-funded health benefit plans will include the Act 77 protections beginning January 2026.
​​Network Adequacy Reporting
Network Adequacy Report Form for this report will be posted on the PID website by April 2025.  Reports are due annually beginning April 1, 2026.
​​Transparency Reporting
​Transparency Reporting Template for this report will be posted on the PID website by April 2025.  Reports are due annually beginning July 1, 2026 (with publication within 60 days of receipt).
† Applies only to fully-funded health benefit plans; individuals covered through a large or small group plan may contact their human resources or benefits administrator to learn whether their plan is a fully-funded health benefit plan subject to Act 77 or a self-funded plan not subject to this law.  For individuals covered through a large group fully-funded health benefit plan, the covered individual may also contact their human resources or benefits administration to learn when the new plan year begins.