Pharmacy Benefit Manager (PBM): Data Submission to the Healthcare Payments Data Program
Overview
Pharmacy Benefit Managers (PBMs) serve as intermediaries between health plans, pharmacies and pharmaceutical manufacturers, and are responsible for administering prescription drug benefits on behalf of health plans. The prescription drug market involves many parties and transactions, making the total cost of prescription drugs difficult to trace. Collecting data from PBMs gives policymakers, researchers, and the public a better view of prescription drug costs in California.
The 2025 State Budget Health Omnibus Bill (Assembly Bill 116) requires HCAI to collect cost data from PBMs. This builds on information HCAI collects from prescription drug manufacturers through the Prescription Drug Cost Transparency Program and pharmacy claims through the Healthcare Payments Data (HPD) Program. Pursuant to Health and Safety Code section 127673.05, PBMs are required to submit data to HCAI as part of the HPD Program. HCAI is also in the process of collecting pharmacy rebate data from health plans through HPD as part of the Non-Claims Payment Data Collection effort.
Per Assembly Bill 116, PBMs now need to be licensed in California. By January 1, 2027, or the date on which the Department of Managed Health Care (DMHC) has established the licensure process, whichever is later, PBMs must be licensed by the DMHC. As a condition of that licensure, PBMs will be required to submit data to HCAI as part of the HPD Program.
Potential PBM Data to be Collected
HCAI intends to collect data from PBMs on drug pricing, fees paid for PBM services, and pharmacy rebates. The data may include:
- Drug codes, names, and therapeutic categories
- Prescription counts
- Patient counts
- Discounts, rebates, fees, and other payments
- Information needed to analyze payments to PBM-owned pharmacies
- Information needed to calculate total net spending, by drug
Regulations Development
HCAI is required to develop regulations before PBM data collection may begin. As such, HCAI will conduct informational interviews with stakeholders who may be directly or indirectly affected by PBM data collection to inform regulation text development and data file specifications. Please reach out to us at pbmdatacollection@hcai.ca.gov to share any general feedback about PBM data collection. HCAI anticipates emergency regulations will be released during Q1 2027. Please subscribe to HPD News and Regulations to stay informed.
HPD Program Advisory Committee
HCAI added a PBM representative to the HPD Advisory Committee. The HPD Advisory Committee meets quarterly and provides guidance to HCAI on the ongoing administration of the database. Including data collection files and formats and setting priorities for public reporting to help address key health policy issues. Meetings are open to the public. The committee does not have decision-making authority but serves as a forum for stakeholder and public engagement fostering accountability and transparency.
Upcoming Activities
Below is the projected timeline and corresponding program activities for PBM data collection through December 2028.
2026-January to June
- Begin evaluating data file formats and specifications.
- Conduct initial outreach to PBMs.
- Perform workshopping on data collection specifications.
- Add PBM representative to the HPD Advisory Committee.
2026-July to December
- Begin developing emergency regulations for data collection.
2027-January to June
- Finish developing emergency regulations for data collection.
- Begin registering PBM data submitters in the HPD System.
- Begin collecting test historical data from PBMs.
2027-July to December
- Complete collecting test historical data from PBMs.
2028-January to June
- Collect production historical data from PBMs.
- Create initial PBM analytic dataset.
2028-July to December
- Begin ongoing data collection from PBMs.
- Include PBM data in first public analytic reports.
Laws and Regulations
Health Care Payments Data Program, Health and Safety Code Section 127671 – 127674.1
Resources
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