DMHC requires contracted PBM information by October 1
Sep 20, 2026 edition · GC-2026-0046 · Published 2026-09-20 · Version 2 · Final
DMHC plans must report contracted PBMs by October 1 and separately ensure licensure before January 2027.
What happened
DMHC’s September 3 APL 26-014 directs health care service plans to submit a Report/Other filing in eFiling on or before October 1, 2026 titled “Contracted PBMs and Pharmacy Delegations.” The required ExhibitE-1 covers each currently contracted PBM and any PBM whose contract will be effective January 1, 2027. It asks for the delegated functions and whether the plan intends to continue the contract beyond that date, making the filing a forward-looking contracting inventory as well as a current-provider list.
The fourth required item is whether the plan has confirmed that each contracted PBM submitted a DMHC licensure application. Application confirmation is distinct from the APL’s reminder that plans must ensure all contracted PBMs are licensed before January 1, 2027. The letter directs questions to the Office of Plan Licensing through the assigned reviewer. At the September 19 cutoff, both the October filing date and January licensing milestone remain ahead; the APL does not establish that any particular plan filed or any named PBM already received 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 both a complete exhibit and a separate licensing-readiness process; an application check alone does not establish licensed status.
Recommended action
Have plan compliance and pharmacy contracting prepare the four ExhibitE-1 fields, reconcile current and January 2027 PBMs, and submit the exact eFiling item by October 1. Track each contracted PBM’s licensing status separately 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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