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PBM Network Adequacy Toolkit

PBM Network Adequacy Toolkit

PBMs must submit the following required documentation in the System for Electronic Rate & Form Filing (SERFF) to demonstrate network adequacy in accordance with MCL 550.827.  PBMs must file the FIS 2390 PBM Network Adequacy Template with the initial application and annually by July 1 beginning in 2025. If applicable, a PBM must also include a FIS 2387 PBM Network Request for Waiver form and exhibits as outlined in section 4 below. If a PBM Network Adequacy Request for Waiver is approved, the PBM must also file a FIS 2387 PBM Network Request for Waiver form and exhibits outlined below in item 4 annually.

Documentation Required For Frequency Annual Due Date
FIS 2390 PBM Network Adequacy Template All PBMs With Application and Annually July 1, beginning in 2025
FIS 2387 PBM Network Adequacy Request for Waiver form PBMs that are requesting, hold, or seek to renew a waiver With Application and Annually July 1, beginning in 2025
Exhibits PBMs that are requesting, hold, or seek to renew a waiver With Application and Annually July 1, beginning in 2025

  1. Obtain Access to SERFF
    PBMs not already registered as a SERFF user should visit SERFF's New User Website and follow the instructions. We recommend completing all steps no later than 1/1/2024.

  2. Participate in SERFF Training
    SERFF training is available through the NAIC:

  3. Review Michigan PBM County Classification and Distance Standards
    The Michigan PBM County Classification and Distance Standards includes the Michigan county classifications, distance standards, and access requirements.

  4. Draft Filing in SERFF
    Log into SERFF and draft a filing under the Type of Insurance: PBM, Sub-Type of Insurance: PBM, and Filing Type: PBM. Please refer to PBM Network Adequacy SERFF Requirements for more details on required SERFF fields.

    1. Complete and submit the FIS 2390 PBM Network Adequacy Template
      The FIS 2390 PBM Network Adequacy Template must contain the details of the PBM’s network(s). Detailed instructions for completing this exhibit are found on the “General Instructions” tab.  DIFS will use this information to verify the PBM meets the network adequacy requirements outlined in the Michigan PBM County Classification and Distance Standards.

      The completed FIS 2390 must be uploaded to SERFF on the Supporting Documentation tab under the “PBM Network Adequacy Report” requirement.

    2. If applicable, complete and submit the FIS 2387 PBM Network Adequacy Request for Waiver form
      If the PBM is unable to meet the network adequacy requirements for one or more networks, the PBM must submit a FIS 2387 PBM Network Adequacy Request for Waiver. The PBM must detail the status of network adequacy for every ZIP code, county, and county classification combination listed. The PBM must include reference to exhibits with the steps the PBM has taken and will take to address network adequacy and specific data on why the PBM is not able to meet the network adequacy requirements at this time.

      The PBM must upload the completed FIS 2387 in SERFF on the Supporting Documentation tab under the “PBM Network Adequacy Request for Waiver Form FIS-2387” requirement.

    3. If applicable, complete and submit the any additional exhibits

      If the PBM applies for a Network Adequacy Request for Waiver, the PBM must also provide:
      • Steps to address network adequacy. This must include a description of any efforts made to contract with providers and evidence of any provider refusals to accept a contract.

      • Specific data demonstrating why the PBM is unable to meet the network adequacy requirements of section 17(1) of the Pharmacy Benefit Manager Licensure and Regulation Act, MCL 550.827(1). This data must include directories, sources consulted, physical geography that affects locations of providers, and any other information that reflects the availability and location of providers.

      The PBM must upload the completed exhibits in SERFF on the Supporting Documentation tab under the “PBM Exhibits” requirement.

  5. Submit Filing and Monitor Progress
    Once all required information and documentation has been uploaded in SERFF, submit the filing. DIFS cannot review any filing in draft form. This filing must be submitted by July 1 each year.

    Once the filing is submitted, DIFS will communicate any questions or concerns via Objections Letters issued on the Filing Correspondence tab in SERFF. The PBM must respond to those objections by the listed due date. Once all objections are resolved and if DIFS approves the network adequacy and/or applicable waivers, the filing will be marked as APPROVED in SERFF. 

Please direct questions regarding PBM network adequacy requirements and submissions to DIFS-PBMNetworks@michigan.gov.