Oct 9, 2025
5 minutes read
The landscape surrounding Pharmacy Benefit Managers (PBMs) is undergoing profound shifts, driven by recent policy developments that have huge implications for market access professionals, field reimbursement managers (FRMs), and prior authorization specialists. These evolving regulations impact operational strategies across payer negotiations, drug pricing, and reimbursement workflows. This blog aims to explore the regulatory context surrounding PBMs and provide actionable insights that will empower professionals to adapt and thrive in this changing environment.
Federal rulings and legislative changes are reshaping the roles and responsibilities of PBMs. For example, a landmark legal challenge in Arkansas recently emphasized the tension between state regulations and federal laws applicable to pharmacy practices. A federal judge ruled against a state law intended to limit PBM practices, highlighting potential constitutional conflicts and the primacy of federal oversight.
For market access professionals, it is essential to recognize how these state and federal fluctuations can influence formulary access and pricing strategies. Regularly monitoring such changes and being responsive to their implications is crucial for developing effective payer engagement strategies.
Transparency Initiatives: Heightened scrutiny on PBM practices has resulted in increasing transparency demands, particularly regarding drug pricing and formulary configurations.
Legislative Changes: Recent federal and state laws are designed to curb anti-competitive practices among PBMs, creating opportunities for enhanced patient access but also necessitating robust compliance measures.
With ongoing regulatory changes impacting drug pricing, it is essential for professionals to regularly reassess their negotiation approaches. Effective strategies now require a deep understanding of payer priorities, including cost containment, value-based agreements, and real-world evidence. By leveraging clinical and economic data, anticipating market shifts, and aligning cross-functional insights, teams can strengthen their value proposition, improve formulary access, and achieve mutually beneficial outcomes for both payers and manufacturers.
The shift toward value-based contracting (VBC) requires stakeholders to demonstrate real-world evidence (RWE) of a drug’s clinical efficacy.
Case Example: Consider a scenario where a new oncology drug shows a significant increase in progression-free survival (PFS) in a specific patient demographic. Here, FRMs should compile comprehensive clinical data, patient testimonials, and cost-effectiveness analyses to make a compelling case for formulary placement.
Changes in PBM regulation significantly influence prior authorization (PA) practices. When formulary structures evolve, the criteria for patient access may also change, potentially leading to increased denial rates.
Consider an FRM collaborating closely with a specialty clinic to compile extensive documentation supporting the medical necessity of a high-cost biologic therapy for autoimmune disorders. By maintaining clear communication channels and regularly updating stakeholders on policy changes, the team enhances its chances of successfully overturning a PA denial.
As legislation increasingly prioritizes operational transparency, the role of data analytics in navigating these changes has become paramount. PBMs must demonstrate compliance with pricing transparency, making it essential for access teams to employ data effectively.
Trend Analysis: Focus on identifying patterns in denial and approval rates through data analytics. This will inform proactive strategies and workflow adjustments.
Root Cause Identification: By analyzing historical PA requests, teams can ascertain the most common reasons for denials and implement targeted interventions to reduce these occurrences.
The future of PBMs is likely to be shaped by a combination of legislative oversight, technology adoption, and a heightened focus on value-driven care. Artificial intelligence (AI) and advanced analytics are poised to revolutionize formulary decision-making, making it possible to predict patient access barriers before they arise. This proactive approach could dramatically improve turnaround times for prior authorizations while reducing administrative burdens on healthcare providers.
Additionally, PBMs will increasingly be expected to demonstrate alignment with patient-centric care models. This means not only negotiating for cost-effective drug pricing but also ensuring equitable access for underserved populations. By integrating patient-reported outcomes and social determinants of health data into reimbursement decisions, PBMs can foster a more holistic approach to market access.
As policy changes accelerate, cross-sector collaboration between PBMs, payers, providers, and pharmaceutical manufacturers will become even more critical. Professionals in market access roles can play a key role by engaging in policy advocacy—sharing real-world insights on how regulations impact patient access and operational efficiency. Building coalitions with professional associations, patient advocacy groups, and health economists will strengthen the case for balanced policies that promote both cost control and patient care.
As PBMs continue to evolve under mounting regulatory scrutiny and shifting healthcare priorities, the professionals who work alongside them—whether in market access, reimbursement, or policy—must remain agile, informed, and proactive. Success will increasingly depend on the ability to navigate policy changes with precision, leverage data to anticipate payer requirements, and collaborate across the healthcare ecosystem to ensure patients receive timely, equitable access to therapies.
For professionals managing prior authorizations, specialized expertise is no longer optional, it is a competitive necessity. Earning the Prior Authorization Certified Specialist (PACS) credential equips stakeholders with the knowledge and practical skills to streamline PA workflows, reduce denial rates, and align processes with both compliance and value-based care imperatives. In an era where PBMs are central to shaping access, PACS-certified professionals will be well-positioned to drive meaningful improvements in patient outcomes while adapting to the future of pharmacy benefits.
How can I reduce turnaround times for prior authorizations?
Consider streamlining your documentation processes and ensuring continuous training for your team on the latest payer requirements.
What steps should I take if a prior authorization is denied?
Engage in a timely and constructive appeals process, gathering all necessary documentation to illustrate medical necessity.
How can I keep current with changes in PBM regulations?
Regularly review updates from authoritative sources, including CMS and FDA, and participate in relevant industry webinars and sessions.
What role does real-world evidence play in payer negotiations?
RWE can effectively demonstrate the clinical benefits and value of therapies, making a strong case for inclusion on formularies.
What strategies assist with managing step therapy requirements?
Familiarize yourself thoroughly with step therapy protocols to provide comprehensive resources for healthcare providers, promoting better navigation of these pathways.
1.Anna Kaltenboeck, Jennifer Chen, Tim Lash. Pharmacy Benefits Manager Reforms: Can Congress Fix the Market Without Breaking It? https://westhealth.org/wp-content/uploads/2024/04/ATI-PBM-Paper_4.15.24.pdf
2. Federal Judge Blocks Arkansas Law Barring Pharmacy Benefit Managers From Owning Pharmacies in State. 2025. https://www.usnews.com/news/best-states/arkansas/articles/2025-07-28/federal-judge-blocks-arkansas-law-barring-pharmacy-benefit-managers-from-owning-pharmacies-in-state
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