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Pharmacy Benefit Managers



The Prescription Drug Reform Act (SB 1550), signed by Governor DeSantis in May 2023, institutes new regulatory requirements for all Pharmacy Benefit Managers (PBMs), including a requirement to become fully regulated as Insurance Administrators.

A pharmacy benefit manager, defined in section 626.88, Florida Statutes (F.S.), means a person or an entity doing business in this state which contracts to administer prescription drug benefits on behalf of a pharmacy benefits plan or program as defined in section 626.8825, F.S. The term includes, but is not limited to, a person or an entity that performs one or more of the following services on behalf of such plan or program:

  • Pharmacy claims processing.
  • Administration or management of a pharmacy discount card program and performance of any other service listed in this subsection.
  • Managing pharmacy networks or pharmacy reimbursement.
  • Paying or managing claims for pharmacist services provided to covered persons.
  • Developing or managing a clinical formulary, including utilization management or quality assurance programs.
  • Pharmacy rebate administration.
  • Managing patient compliance, therapeutic intervention, or generic substitution programs.
  • Administration or management of a mail-order pharmacy program.

This page provides information and resources on statutory requirements for PBMs. 

Filing a Complaint

Complaints on issues regarding PBMs can be made to the Department of Financial Services (DFS), Division of Consumer Services by emailing For more information, please visit the DFS Consumer Services website here.

Complaints on PBM issues regarding Florida Medicaid providers should be submitted to the Agency for Health Care Administration (AHCA). More information is available on AHCA's website here.



Application for Certificate of Authority

Beginning on January 1, 2024, PBMs operating in Florida must continue to be registered with the OIR, using the form linked below (section 624.490, F.S.), and hold a valid certificate of authority (COA) as an administrator (sections 626.88 and 626.8805, F.S.). Additionally, the Prescription Drug Reform Act requires that PBMs submit the following documentation to OIR:

  • A self-disclosure of any administrative, civil, or criminal complaints, settlements, or discipline, or any of its affiliates, which relates to a violation of the insurance laws, including pharmacy benefit manager laws, in any state.
  • A statement attesting to compliance with the network requirements in Section 626.8825, Florida Statutes. Companies may also wish to submit supporting documentation (i.e. Network Files, Analyses, etc.) to the attestation to ensure compliance with the requirements set forth in Chapter 626, Florida Statutes.  
  • A statement identifying any ownership affiliation of any kind with any pharmacy which, directly or indirectly, through one or more intermediaries: Has an investment or ownership interest in a PBM holding a Florida certificate of authority; shares common ownership with a PBM holding a Florida certificate of authority; or has an investor or a holder of an ownership interest which is a PBM holding a Florida certificate of authority.
  • A PBM shall also make available to the OIR copies of all contract templates with any pharmacy as defined in Section 465.003, Florida Statutes, and copies of all subcontracts to support the company's operations. This includes copies of all contract templates between the PBM and any pharmacy benefit plan or program as defined in Section 626.8825(u), Florida Statutes.

Upon receipt and review of a complete application by a PBM that meets the requirements of Florida Law, the OIR will issue a COA.

Any PBM operating in Florida without a valid COA beginning on January 1, 2024, will be subject to a fine of $10,000 per violation per day.

The application form is available here.

Transparent Reporting Requirements

Contract Provisions, Patient Data Practices, & Prohibited PBM Practices