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Pharmacy benefit managers (PBMs) should consider the
implications of a model law making its way through the National
Association of Insurance Commissioners (NAIC) that would establish
a licensure requirement and rules of conduct for these participants
in the health care marketplace. A number of states have already
adopted their own PBM laws, and an NAIC model would be likely to
motivate others to do so.
On April 12, 2021, the NAIC's Health Insurance and Managed
Care Committee, meeting by videoconference at the NAIC's Spring
National Meeting, briefly discussed the PBM Model Act, agreeing to