Pass-Through Rebate Law Uncovering New PBM Tactics, Entities | NCPA 2025

Pharmacy benefit manager (PBM) tactics have been notably uncovered on a rolling basis at the state and federal levels in recent history. As states enact laws amid PBM reform pressure, experts in pharmacy and the pharmacists themselves are uncovering ways in which PBMs continue to evade reform laws through things like rebate aggregators.

“Rebate aggregators are not PBMs,” Dae Lee, PharmD, Esq, CPBS, shareholder with Buchanan Ingersoll & Rooney, told Drug Topics. “Whatever the rebates that are being retained by those rebate aggregators, and the fees paid by the manufacturers to the rebate aggregators, off of the wholesale acquisition costs or [rebated] cost, are not being passed through.”

Through Utah’s introduction of house bill 0257, the state is now enforcing that rebates on prescription drugs be passed through to the insurance beneficiary instead of PBMs being able to pocket them for their own profit.¹

To get a better grasp on this law, what it means for the greater PBM industry, and how PBMs are reacting to it, Lee and his colleague, Lucas Morgan, Esq, also a shareholder with Buchanan Ingersoll & Rooney, joined Drug Topics during the National Community Pharmacists Association (NCPA) 2025 Annual Convention & Expo.

From newly known knowledge regarding rebate aggregators to the common yet opaque operations of the “Big 3” PBMs, the duo shared insights in part 2 of our interview on the current ongoings of PBM reform on the state level. Stay tuned for more as Lee and Morgan bounce around and discuss a variety of PBM reform laws impacting several states and how they may show potential to reach sentiments of PBM reform on the federal level.

Read more of our coverage from NCPA 2025.

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REFERENCE

Kimbrough L. Pharmacy benefit manager reform: how states are changing PBM operations. Multistate. August 7, 2025. Accessed October 27, 2025. https://www.multistate.us/insider/2025/8/7/pharmacy-benefit-manager-reform-how-states-are-changing-pbm-operations