DMHC requires contracted PBM information by October 1
Sep 6, 2026 edition · GC-2026-0046 · Published 2026-09-06 · Version 2 · Final
DMHC’s September 3 APL requires an October 1 PBM filing and separate licensing readiness before January 2027.
What happened
APL 26-014 requires health care service plans to submit a Report/Other item through eFiling on or before October 1, 2026 using the title “Contracted PBMs and Pharmacy Delegations.” Its ExhibitE-1 must identify currently contracted PBMs and PBMs with contracts effective January 1, 2027, list delegated functions and state whether contracting will continue beyond that date. The filing is therefore both a current inventory and a forward-looking contract review.
The exhibit also asks whether the plan confirmed that each contracted PBM submitted a DMHC license application. That confirmation is separate from ensuring all contracted PBMs are licensed before January 1, 2027, as the APL reminds plans. Questions go through the assigned Office of Plan Licensing reviewer. Both dates remain future at the September 5 cutoff; the letter does not prove that a plan has filed or that a particular PBM holds a license.
Scope and timing
- Authority status
- Final
- Applicability
- Potentially applicable
- Audience
- Health systems, Provider networks
- Jurisdiction
- California
- Recorded date
- 2026-10-01
- Date type
- compliance
Why it matters
Plans need complete contracting data and an independent licensing-readiness check rather than treating an application as a license.
Recommended action
Assign plan compliance and pharmacy contracting to prepare all four exhibit fields and the October 1 filing, reconcile January contracts, and track contracted PBM licensing before January 1.
Sources
- APL 26-014: Contracted Pharmacy Benefit Manager InformationOfficial · California Department of Managed Health Care · 2026-09-03 · Source review 2026-09-06
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