NACDS thanks Congress for taking a historic step by enacting the most significant federal PBM reforms advanced to date in the Consolidated Appropriations Act, 2026. These reforms reflect years of bipartisan efforts to confront harmful PBM practices—and they must be implemented swiftly and consistent with Congressional intent.

Reforms enacted include a necessary element of real reform: requiring the Centers for Medicare & Medicaid Services (CMS) to define and enforce “reasonable and relevant” Medicare Part D contract terms, including information about reimbursement and dispensing fees, and establishing in Medicare Part D an approach by which “any willing pharmacy” can truly participate and serve patients.

At the same time, more action is needed now to address continuing PBM tactics and protect patient access. NACDS urges Members of Congress to support top-priority remaining reforms, including: a Medicaid managed care pharmacy payment rate floor, a ban on spread pricing, and requiring 100% pass-through of transparent rates, which includes ingredient cost and dispensing fee, to the pharmacy.

States are recognizing the need to enact PBM reform – and to press forward with implementation, enforcement, and oversight despite PBMs’ efforts to roll back reforms. From 2021 to 2025, states have enacted more than nearly 250 new PBM reform laws. One or more aspects of the NACDS Principles of PBM Reform now have been adopted in every state – though much, much more work is needed in the states. Further, this does not in any way mitigate the need for federal action on the issues that it must address.