DMHC requires contracted PBM information by October 1

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.

Why it matters

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

Sources

• APL 26-014: Contracted Pharmacy Benefit Manager InformationOfficial · California Department of Managed Health Care · 2026-09-03 · Source review 2026-09-06