DMHC requires contracted PBM information by October 1
Sep 27, 2026 edition · GC-2026-0046 · Published 2026-09-27 · Version 2 · Final
DMHC requires contracted-PBM information by October 1 and reminds plans of PBM licensing before January 1, 2027.
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.
Recommended action
Prepare and submit the named Report/Other filing and Exhibit E-1 by October 1, reconcile every PBM and delegation, and preserve confirmation evidence while tracking actual licensing before January 1, 2027.
Sources
- APL 26-014: Contracted Pharmacy Benefit Manager InformationOfficial · California Department of Managed Health Care · 2026-09-03 · Source review 2026-09-06
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 →