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ACTION REQUIRED TO AVOID FINES! DEADLINE APPROACHING: Florida Pharmacy Benefit Managers Must Be Licensed as a Third-Party Administrator by January 1, 2024

By Thomas A. Range & Bruce D. Platt on October 20, 2023
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Pharmacy Benefit Managers (PBMs) take note! Under Florida’s new Prescription Drug Reform Act, PBMs must be licensed as an insurance administrator (also known as a third-party administrator, or TPA). Under this new law, any entity that wishes to provide PBM services after January 1, 2024, must be licensed as a TPA.

The Florida Office of Insurance Regulation (OIR) has adopted a new TPA license application that incorporates the additional licensing requirements for PBMs. The TPA license application is available here. For an entity that is not currently registered as a PBM, that entity will, in addition to obtaining a TPA license, have to register as a PBM. The PBM registration form is available here.

Based on informal conversations with the OIR, we understand that many of the currently registered PBMs have not submitted their TPA license applications. The TPA licensing process can take several months, especially if a significant number of applications are submitted at or around the same time. We strongly encourage existing PBMs that wish to continue providing PBM services after January 1, 2024, to submit the TPA licensing application materials as soon as possible because the Act includes significant penalties and public scrutiny for unlicensed activities. See § 626.8805(1), Florida Statutes:

A person who, on or after January 1, 2024, does not hold a certificate of authority to act as an administrator while operating as a pharmacy benefit manager is subject to a fine of $10,000 per violation per day (emphasis added). By January 15, 2024, the [OIR] shall submit to the Governor, the President of the Senate, and the Speaker of the House of Representatives a report detailing whether each pharmacy benefit manager operating in this state on January 1, 2024, obtained a certificate of authority on or before that date as required by this section.

For more information on the Prescription Drug Reform Act, please see our previous blog. Akerman has significant experience with TPA licensing and the OIR’s licensing process and is available to assist with the preparation and submission of license applications.

Photo of Thomas A. Range Thomas A. Range

Having spent nearly a decade working for a national biopharmaceutical company, including five years in management, Tom Range possesses invaluable experience in the biotechnology sector, which allows him to better serve his broad client base.  Because he has worked in facilities regulated by…

Having spent nearly a decade working for a national biopharmaceutical company, including five years in management, Tom Range possesses invaluable experience in the biotechnology sector, which allows him to better serve his broad client base.  Because he has worked in facilities regulated by the FDA, the State of Florida, and foreign authorities, Tom understands the challenges facing companies whose success depends on their ability to navigate often-murky regulatory waters.

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Photo of Bruce D. Platt Bruce D. Platt

Bruce Platt serves as managing partner of Akerman’s Tallahassee office. With a background in healthcare and medical technology, he helps insurers, providers, and related companies navigate federal and state regulations and administrative law. Clients rely on Bruce for guidance on complex regulations, such…

Bruce Platt serves as managing partner of Akerman’s Tallahassee office. With a background in healthcare and medical technology, he helps insurers, providers, and related companies navigate federal and state regulations and administrative law. Clients rely on Bruce for guidance on complex regulations, such as the Florida Insurance Code, HIPAA, and the Affordable Care Act. His clients include Aetna, AvMed, Florida Blue, Health First, and UnitedHealthcare, among others.

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  • Posted in:
    Health Care and Life Sciences
  • Blog:
    Health Law Rx
  • Organization:
    Akerman LLP
  • Article: View Original Source

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