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Navigating the Evolving Landscape of State PBM Laws

By Susie Bilbro, Will Gebo & Nicole Roth on November 3, 2025
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The legal landscape for pharmacy benefit managers (PBMs) continues to shift as states pass new laws and courts weigh in on how those laws interact with federal ERISA requirements. These developments are creating new challenges for self-funded health plans trying to stay compliant.

In our recent article for HR.com, we examined several key updates, including how a portion of Tennessee’s PBM law has been found to be preempted by ERISA, while certain Arkansas reporting requirements are not. We also discussed the start of enforcement of Florida’s reporting obligations and Texas’ position that its PBM legislation is not preempted by ERISA.

We shared insights on what these changes mean for plan sponsors and how state-level PBM reform continues to evolve. As we noted in the article, “Given the recent increase in prescription drug legislation and related litigation, state-level PBM reform and its impact on self-funded ERISA plans are continuously evolving. Staying informed on new laws, ERISA preemption challenges and related developments is critical for self-funded ERISA plan sponsors to avoid being caught in a shifting landscape without a map.”

The full article, “State PBM Laws: A Complicated Landscape for Self-Funded Health Plans to Navigate,” was published by HR.com on October 28 and is available online.

Photo of Susie Bilbro Susie Bilbro

Susie Bilbro advises clients on all aspects of employee benefit plan design and administration including compliance with ERISA, the Patient Protection and Affordable Care Act (healthcare reform), COBRA and the Internal Revenue Code. She has counseled public and private clients on employee welfare…

Susie Bilbro advises clients on all aspects of employee benefit plan design and administration including compliance with ERISA, the Patient Protection and Affordable Care Act (healthcare reform), COBRA and the Internal Revenue Code. She has counseled public and private clients on employee welfare and pension benefits issues, both in connection with corporate transactions and on day-to-day administration. In addition, Susie has prepared submissions to the IRS and Department of Labor for qualified retirement and welfare benefit plans. Susie also has experience advising clients on executive compensation arrangements.

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Photo of Will Gebo Will Gebo

Will Gebo works with clients on the design, implementation and administration of qualified benefit plans, health and welfare benefit plans and deferred compensation packages. He also provides diligence and support on employee benefits and compensation issues arising in mergers, acquisitions and other corporate…

Will Gebo works with clients on the design, implementation and administration of qualified benefit plans, health and welfare benefit plans and deferred compensation packages. He also provides diligence and support on employee benefits and compensation issues arising in mergers, acquisitions and other corporate transactions.

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Photo of Nicole Roth Nicole Roth

Nicole Roth works with clients on the design, implementation, and administration of qualified benefit plans, health and welfare benefit plans, and deferred compensation packages. She also provides diligence and support on employee benefits and compensation issues arising in mergers, acquisitions, and other corporate…

Nicole Roth works with clients on the design, implementation, and administration of qualified benefit plans, health and welfare benefit plans, and deferred compensation packages. She also provides diligence and support on employee benefits and compensation issues arising in mergers, acquisitions, and other corporate transactions.

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  • Posted in:
    Health Care and Life Sciences
  • Blog:
    HR Law Talk
  • Organization:
    Bass, Berry & Sims PLC
  • Article: View Original Source

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