DMHC requires contracted PBM information by October 1
Oct 11, 2026 edition · GC-2026-0046 · Published 2026-10-11 · Version 3 · Final
DMHC's September 3 APL required plans to file contracted-PBM and pharmacy-delegation information by October 1. The deadline has passed for this edition, while the separate requirement to ensure contracted PBMs are licensed before January 1, 2027 remains an implementation issue.
What happened
APL 26-014 addresses all health care service plans and reminds them of PBM licensing requirements under the identified statutes and All Licensee Letter 26-010. It directs plans to ensure every contracted PBM is licensed before January 1, 2027. Separately, plans had to submit an eFiling Report/Other on or before October 1, 2026, titled Contracted PBMs and Pharmacy Delegations, containing at least an Exhibit E-1. The letter's September issuance and already-elapsed filing date make this an implementation carryover for October 11 rather than a new filing announcement.
Exhibit E-1 must identify every currently contracted PBM and PBM whose contract will be effective January 1, 2027, the delegated functions for each, and whether the plan intends to keep contracting with it beyond January 1. The fourth item asks whether the plan has confirmed that each contracted PBM submitted a DMHC license application. Reporting application confirmation is distinct from ensuring actual licensure before January 1. The source establishes what plans had to submit and verify, without establishing that a particular plan filed, that its report was complete, or that a PBM's application resulted in 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
The filing applies to regulated plans, including relevant system-affiliated plans. It covers current PBMs and contracts effective January 1, 2027, their delegated functions, continued contracting intentions, and confirmation of license applications.
Recommended action
Plan compliance and pharmacy contracting should reconcile the October 1 Report/Other filing titled Contracted PBMs and Pharmacy Delegations against every current and January 2027 PBM; resolve any missing filing or application confirmation and verify licensure before January 1.
Sources
- APL 26-014: Contracted Pharmacy Benefit Manager InformationOfficial · California Department of Managed Health Care · 2026-09-03 · Source review 2026-10-11
Complete edition and supplemental material
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