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DMHC requires contracted PBM information by October 1

DMHC's contracted-PBM filing was due October 1; on October 4 plans should verify submission and follow up on licensing readiness before January 1, 2027.

What happened

DMHC's September 3, 2026 All Plan Letter 26-014 directs health care service plans to submit contracted pharmacy benefit manager information by October 1, 2026. The letter specifies an eFiling Report/Other submission titled 'Contracted PBMs and Pharmacy Delegations,' including an Exhibit E-1. The exhibit must identify each currently contracted PBM and each PBM whose contract will be in effect January 1, 2027, and describe delegated functions. By this October 4 issue, the filing date has passed; the appropriate task is to confirm the submission or address an identified omission, rather than describe October 1 as an upcoming deadline.

The exhibit also asks whether the plan intends to continue contracting with each listed PBM beyond January 1, 2027 and whether it confirmed that each PBM submitted a licensure application. Those are separate questions: confirmation of an application does not by itself establish that a license has been issued. The letter reminds plans to ensure contracted PBMs are licensed before January 1, 2027, citing the governing legislation and prior all-licensee guidance. It directs questions about the checklist or letter to the Office of Plan Licensing through the assigned reviewer. Plans therefore need both a complete filing record and continuing evidence of each PBM's licensing status.

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 past reporting deadline and future licensing requirement require different controls, especially where delegated services or planned contracts change.

Sources

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