Compliance SweepBack to stories →
← Back to stories

DMHC requires contracted PBM information by October 1

DMHC requires contracted-PBM information by October 1 and reminds plans of PBM licensing before January 1, 2027.

Illustrative artwork. Fictional scene, not a photograph of the people or events in this story.

What happened

DMHC’s September 3 APL26-014 directs health care service plans to file contracted-PBM information on or before October 1, 2026. The filing goes through eFiling as Report/Other with the title Contracted PBMs and Pharmacy Delegations and must include at least Exhibit E-1. The letter separately reminds plans to ensure all contracted PBMs are licensed before January 1, 2027. At the September 26 coverage end, the October filing deadline is still upcoming; filing an application and holding a license are distinct states.

Exhibit E-1 must identify each currently contracted PBM and each PBM whose contract will be effective January 1, 2027, list delegated functions, state whether the plan intends to continue contracting beyond that date, and say whether the plan confirmed each contracted PBM submitted a licensure application. Those questions require reconciliation between pharmacy contracting, delegation inventories and the plan’s regulatory filing. The APL points questions to the assigned licensing reviewer; it does not state that merely naming a PBM or confirming an application satisfies the separate January licensing requirement.

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

The plan must reconcile current and future contracts and delegated functions while tracking application confirmation separately from actual licensure.

Sources

Complete edition and supplemental material

This finding in the complete approved report →

Regulatory horizons, CIA trends and implementation trackers remain in the full report.

Read the entire Compliance Sweep report →

← Return to stories

Privacy preferences

Where enabled for this site, Cloudflare Web Analytics can send page-use and performance measurements to Cloudflare. This panel provides information and does not turn analytics on or off.

This panel stores no tracking choice and does not change your tool saves, screening, resets, reports or exports. Other sites have separate settings.

Read Privacy & Cookies