←State PenaltiesPBM Regulatory Penalties — All 50 States
PBM Regulatory Penalties — All 50 States
Pharmacy Benefit Manager regulations: spread pricing bans, rebate pass-through, fiduciary duties, and licensing enforcement.
Color-coded by maximum civil fine severity
Risk tier:HighMediumLow
| State | Tier | Law | Civil Fine | Key Provisions | Imprisonment |
|---|---|---|---|---|---|
| Alabama | Low | SB 252 (Community Pharmacy Relief) | $1,000/violation | $10.64 dispensing fee; ALDOI enforcement | N/A |
| Alaska | Low | SB 132/SB 134 | $2,500/violation | $20K license required | N/A |
| Arizona | Low | SB 1102 / DIFI | $1,000/violation | Cease-and-desist authority | 4 months (Class 2 Misd.) |
| Arkansas | High | Act 624 (Ownership Ban) | $1,000/violation/day | License revocation for ownership violations | N/A |
| California | High | SB 40 (Insulin cap) | $35M historic (DMHC) | $35/month insulin copay cap | 6 months |
| Colorado | High | Insurance Commissioner | $1,000/violation/day | Registration denial/revocation | N/A |
| Connecticut | High | Insurance Commissioner | $100,000/violation | Fiduciary duty established Oct 2025 | N/A |
| Delaware | Medium | Insurance Commissioner | $10,000/violation | Authority revocation possible | N/A |
| Florida | High | FL Office of Insurance Reg. | $10,000/violation/day | Spread pricing prohibited | N/A |
| Georgia | Medium | HB 690 | $10,000/act (willful) | Private right of action established | N/A |
| Hawaii | Medium | HB 2225 | $10,000/violation | Unfair/deceptive acts enforcement | N/A |
| Idaho | Low | ID Code § 41-349 | Admin fines + license loss | Spread pricing ban; 100% rebate pass-through | N/A |
| Illinois | Low | Insurance Code | Regulatory action | Director of Insurance enforcement | N/A |
| Indiana | Medium | SB 140 / HB 1606 | $10,000 (3rd+ violation) | $1K first; $2.5K second; license suspension | N/A |
| Iowa | Low | SF 383 | Admin penalties + license | Federal legal challenges ongoing | N/A |
| Kansas | High | SB 360 | $100,000 (unlicensed) | Strict licensing; cease-and-desist | N/A |
| Kentucky | Low | SB 188 / 201 KAR 2:416 | $500 (late renewal) | $10K registration fee; DOI enforcement | N/A |
| Louisiana | Low | PBM Reform Act 2025 | $1,000/claim | Treble damages; enforcement fund | N/A |
| Maine | High | LD 1580 | $5,000/day (unlicensed) + $500K market | Spread pricing ban; $500K market withdrawal penalty | <1 year |
| Maryland | Medium | SB 896 | $10,000/violation | $1K/day carrier penalties; restitution | N/A |
| Massachusetts | High | Eff. Jan 2026 | $25,000 (false reporting) + $5K/day | 10% surcharge on unlicensed operations | N/A |
| Michigan | Medium | PA 11 of 2022 | $20,000/month (suspended) | License revocation; DIFS oversight | N/A |
| Minnesota | High | Dept. of Commerce | $25,000/violation | $10K/day unlicensed; fiduciary duty | N/A |
| Mississippi | High | HB 1672 | $25,000 (admin) + $1K/day general | Board of Pharmacy enforcement | N/A |
| Missouri | High | SB 846/SB 363 | $5,000/violation/day | Probation up to 5 years; license revocation | N/A |
| Montana | Low | HB 740 | Insurance code violations | Spread pricing ban; retroactive denial ban | N/A |
| Nebraska | Low | LB 198 (eff. Jan 2026) | $1,000/entity/violation | Spread pricing ban; specialty pharmacy rights | N/A |
| Nevada | Low | Single State PBM | Admin fines + registration revocation | Spread pricing ban; transparency reports | N/A |
| New Hampshire | Medium | SB 478/SB 547 (proposed) | $10,000/violation | Fiduciary duty; gag clause ban | Misd./Felony possible |
| New Jersey | High | S1300 | $10,000/day (non-compliance) | $5K first; $10K subsequent; gross receipts recovery | N/A |
| New Mexico | Medium | PBM Regulation Act | $1,000–$10,000/incident | Spread pricing ban; audit protections | N/A |
| New York | Low | DFS oversight | $1,000–$5,000/violation | License suspension/revocation | Perjury possible |
| North Carolina | Medium | Dept. of Insurance | $500–$50,000/violation | Spread pricing ban; rebate pass-through | N/A |
| North Dakota | Medium | HB 1584 | $10,000/vio ($50K subsequent) | Enforcement fund; $1M financial responsibility bond | 5 years (Class C Felony unlicensed) |
| Ohio | High | ORC 3959 | $1,000/violation/day | Superintendent license revocation | 30 days (4th degree misd.) |
| Oklahoma | Low | Patient's Right to Pharmacy Choice | $100–$10,000/violation | License revocation; $50K–$500K surety bonds | N/A |
| Oregon | Medium | Insurance Code | $10,000/violation | $10K/day transparency reporting; cost growth | N/A |
| Pennsylvania | High | Act 77 of 2024 | $100,000/violation ($1M/year cap) | $50K unknown violations; $500K/year cap | N/A |
| Rhode Island | Medium | S0222 / OHIC | $10,000/violation | NADAC + dispensing fee minimum | N/A |
| South Carolina | Medium | SC Dept. of Insurance | $10,000/violation | 104% NADAC + dispensing fee; anti-steering | N/A |
| South Dakota | Low | SDCL 58-29E | License revocation + damages | Fee ban; anti-clawback; MAC list updates | N/A |
| Tennessee | Low | SB 881/HB 1244 | $250K cap removed — aggressive | TDCI consent orders; aggressive enforcement | N/A |
| Texas | Low | SB 1122/SB 1354 | $1,000–$5,000 | Pharmacy appeal rights; cost + dispensing fee | N/A |
| Utah | Low | HB 257 | Admin fines | Spread pricing ban; drug synchronization | N/A |
| Vermont | High | DFR Licensure | $100,000/violation | Spread pricing ban; gag clause ban | License revocation |
| Virginia | Medium | SCC Title 38.2 | $5,000/day | License revocation; private right of action | N/A |
| Washington | Low | RCW 48.200 | $5,000 (willful) | $1K standard; OIC oversight | N/A |
| West Virginia | Medium | HB 3092 / OIC | $20,000 (unlicensed) + $10K/violation | 100% rebate pass-through required | N/A |
| Wisconsin | Low | Cole's Act / SB 203 | Admin fines + license revocation | Medicaid dispensing fee; gag clause ban | N/A |
| Wyoming | Low | WY PBM Act | $1,000 (willful) | 2-year audit lookback; patient choice | Misdemeanor |