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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