The PBM Policy and Legislative Update — Spring 2025 edition builds upon prior issues and summarizes activity from January through March (2025) that affects the PBM industry. It highlights federal activities, state activities, and other noteworthy events and trends affecting the PBM industry.

On April 16, 2025, Arkansas enacted Act 624 (the Act), an unprecedented law prohibiting pharmacy benefit managers (PBMs) from owning or operating pharmacies in the state. As we discussed in our May 2025 blog post, the law’s passage has already resulted in market disruptions, and PBMs with vertically integrated business models have cautioned that the law will limit patients’ access to drugs and cost many local jobs. 

Now, two of the nation’s largest PBMs, CVS Health and Cigna’s Express Scripts (ESI), have filed federal lawsuits seeking to block implementation of the Act on the grounds that the Act is unconstitutional, preempted by federal law, and harmful to Arkansans. 

Arkansas Governor signed Act 624 on April 16, 2025, banning PBMs from acquiring or holding a direct or indirect interest in a pharmacy. This state-led move may inspire similar laws elsewhere.

Mintz’s Pharmacy Benefits and PBM Contracting Practice is pleased to present the ‘Fourth Edition: Q1 2025’ of our Mintz IRA Update, a regular publication that delves into developments of the Inflation Reduction Act of 2022 (IRA) and their impact on pharmaceutical supply chain stakeholders.

The PBM Policy and Legislative Update — Winter 2025 edition builds upon prior PBM Policy and Legislative Updates and summarizes activity from October through December (2024) that affects the PBM industry. It highlights (i) federal activities, (ii) state activities, and (iii) other noteworthy events and trends affecting the PBM industry.

On January 13, 2025, California Attorney General Rob Bonta (the California AG) issued two Legal Advisories regarding the utilization of artificial intelligence (AI). The first Legal Advisory provides guidance to consumers and entities developing, selling, and using AI describing their rights and obligations under California law. The second Legal Advisory, entitled Application of Existing California Law to Artificial Intelligence in Healthcare (the Health Care Legal Advisory), is expressly directed at health care providers, insurers, vendors, investors, and other health care entities who develop, sell, and use AI and other automated decision-making tools.

Governor Newsom signed over 1300 bills and vetoed almost 190 bills in 2024.  Consistent with prior years, in 2024, California enacted multiple laws significantly impacting the health care industry.  From artificial intelligence (AI) to providers to health plans, these new laws require proactive efforts to ensure on-going compliance.

We highlight below the most important of the heath care-focused bills passed during this year.  Unless otherwise noted, these new laws are effective January 1, 2025.

Building upon prior issues and summarizing activity from July through September, the Fall 2024 PBM Update highlights federal legislative activity and oversight, state legislative activity and oversight, and other noteworthy events and trends affecting the PBM industry.

In ‘Third Edition: Q2 2024’ of the Mintz IRA Update, we cover updates to the Medicare Drug Price Negotiation Program being considered by CMS, developments in litigation challenging the program, the consequences and costs of redesigning the Part D program, opposition to the use of march-in rights to lower drug prices, and the growing use of state prescription drug affordability boards.