Posted 12/22/2025
A PBM not exempted by MCL 550.833(5) that believes it does not have reporting responsibilities to DIFS must provide a thorough justification as to why it does not meet the criteria for reporting under the "Zero Reporting" section of the FIS 2396 "Contact Info & Instructions" tab.
A PBM not exempted by MCL 550.833(5) that believes it does not have reporting responsibilities to DIFS must provide a thorough justification as to why it does not meet the criteria for reporting under the "Zero Reporting" section of the FIS 2396 "Contact Info & Instructions" tab.
DIFS uses U.S. Pharmacopeia (USP) categories for the reporting requirement under MCL 550.833(2)(a). USP provides a free download of their category hierarchy at www.usp.org.
Reporting PBMs should make every effort to map products to a USP category. For products that cannot be mapped to any category, a separate category titled “Products without a USP Category” may be used. This category should only be used in instances where a product cannot be reasonably assigned to an existing USP category by the PBM.
In cases where a product may be mapped to more than one USP category, a PBM should choose only one USP category. PBMs are encouraged to select the most appropriate USP category if one exists. If no USP category is most appropriate, the category choice is at the discretion of the PBM.
There are free resources available to help translate products to USP Category. The UMLS RxNorm Files assists in mapping NDC to RxCUI, and the CMS EHB Rx Crosswalk assists in mapping RxCUI to USP Category.
The date by which a PBM must file a transparency report is set by law. See MCL 550.833(1). PBMs unable to comply with the statutory due date are strongly encouraged to submit their reports as soon as possible thereafter. Failure to timely file a transparency report may be grounds for disciplinary action.
PBMs that applied for licensure during the reporting year and did not subsequently withdraw their application must submit a FIS 2396.
