PBM Regulation & Enforcement Updates

We continue to monitor notable developments affecting Pharmacy Benefit Managers (PBMs), including:

• Ohio passed a new PBM law (effective July 1, 2027) adding licensing, transparency, and consumer protection requirements.
• Tennessee PBM laws were partially struck down as ERISA‑preempted for self‑funded plans by the Sixth Circuit Court of Appeals.
• Express Scripts/Cigna were named in a RICO class action alleging rebate and kickback misconduct; the case is ongoing.

We’ll continue tracking these developments and share updates as they evolve.