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The Pharmacy Benefit Manager (PBM) Licensure and Regulation Act, PA 11 of 2022, takes effect on January 1, 2024. This law introduces new licensing obligations and regulatory standards for PBMs operating in Michigan. To remain in compliance, DIFS strongly encourages PBM applicants and licensees to review the statute and administrative rules and to monitor DIFS guidance.
A Pharmacy Benefit Manager (PBM) must also be certified as a Third Party Administrator (TPA). Here are the instructions for applying for a TPA Certificate of Authority.
In addition, a PBM seeking licensure in Michigan must submit the following:
For the PBM pharmacy network adequacy report referenced in the application, please see the PBM Network Adequacy Toolkit for full submission instructions.
Pursuant to section 11(3) of the Pharmacy Benefit Manager Licensure and Regulation Act, MCL 550.821(3), a Pharmacy Benefit Manager (PBM) must file any significant modification of information submitted with the application for a license within 30 days of the significant modification. See also Mich Admin Code, R 500.33(3). Significant modifications include:
To file a modification, please complete the FIS 2392 Pharmacy Benefit Manager Modification of Information and submit it to DIFS-PBMLicensing@michigan.gov or by postal mail to:
DIFS General Mailing Address:
Department of Insurance and Financial Services
PO Box 30220
Lansing, MI 48909-7720
Delivery / Street Address:
Department of Insurance and Financial Services
530 W. Allegan Street, 7th Floor
Lansing, MI 48933
A PBM must renew its license by July 1 every two years. The first year in which renewal should take place is determined by the year of initial license approval. For example, if the license was issued on February 15, 2024, submission of the first renewal is required by July 1, 2026, then July 1 every two years thereafter. The renewal portal will open every May 1. If the renewal is not completed by July 1 of the PBM’s renewal year, the PBM license will be inactivated by July 15 of the same year.
In order to renew a license, the PBM must submit the following:
More information on PBM license renewals is forthcoming.
By April 1, 2025, and each April 1 thereafter, a PBM must file a transparency report with DIFS. The transparency reporting requirement does not apply to a contract between a PBM and the Department of Health and Human Services related to the Medicaid program. More information on transparency reporting requirements is forthcoming.
A PBM may request a duplicate license or certificate of good standing at no cost. Requests may be made here: Document Requests - Certification Letter, Duplicate License, License History.
