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Pharmacy Benefit Managers

The Pharmacy Benefit Manager (PBM) Licensure and Regulation Act, PA 11 of 2022, took effect on January 1, 2024. This law introduced 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.

Application Process

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.

Bulletin 2023-23-INS Pharmacy Benefit Manager License Application Process and Fee

Information for Licensed PBMs

PBM Modification of Information

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:

  • administrative action taken against the PBM or any individual responsible for the conduct of the affairs of the PBM by another state;
  • changes to basic organizational documents;
  • changes to the person or address designated to receive service of process if the PBM is not domiciled in this state;
  • criminal felony proceedings for any individual responsible for the conduct of the affairs or has ownership of 10% or more of the PBM;
  • significant changes (material) in the financial condition of the PBM;
  • additions or removal of individuals responsible for the conduct of the affairs of the PBM;
  • changes in the ownership of the PBM of 10% or more; and
  • changes in the description of the PBM, its services, facilities, and personnel.

To file a modification, please complete the FIS 2392 Pharmacy Benefit Manager Modification of Information and submit it to 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

PBM License Renewals

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.

PBM Transparency Reporting

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.

Duplicate License/Certificate of Good Standing

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.

Filing a Complaint with DIFS

We encourage consumers and pharmacies to first attempt to resolve their disputes directly with the PBM. If a resolution cannot be reached, our office can help try to resolve your dispute. Our Call Center Specialists are available to help you Monday through Friday, from 8 a.m. to 5 p.m. at 877-999-6442.

Complaints can be submitted in the following ways: