Three terms, briefly
Pharmacy benefit managers
Companies that run prescription drug benefits for insurers, employers, and public programs. They negotiate rebates with manufacturers, set what pharmacies are paid, and manage formularies, the lists of drugs a plan covers. States regulate them mainly through insurance law.
Affordability boards
State boards that review the cost of specific high-priced drugs. Some only study and recommend. Others can set an upper payment limit, the most that covered purchasers in the state will pay for a drug.
340B contract pharmacies
Under a federal program, drug manufacturers that take part in Medicaid must offer discounted prices to certain hospitals and clinics, which often dispense through outside pharmacies. Since 2020, many manufacturers have limited discounts on drugs sent to those pharmacies; some states have passed laws barring those limits.
Side-by-side comparison
Choose which states to compare. On a phone, scroll the table sideways. Where a detail rests on a secondary source rather than a statute, regulation, court order, or legislative record, the table says "as reported."
Showing:
| Pennsylvania | Virginia | Ohio | Maryland | Georgia | |
|---|---|---|---|---|---|
| Pharmacy benefit managers | |||||
| Regulator and license | Registration with the Insurance Department under Act 77 of 2024, which applies to fully insured plans. | License from the State Corporation Commission's Bureau of Insurance (Va. Code § 38.2-3465 et seq.). | HB 229 (2026) creates a PBM license under the Superintendent of Insurance (R.C. Chapter 3957), effective June 30, 2026, with the license required from July 1, 2027. | Registration with the Maryland Insurance Administration (Insurance § 15-1601 et seq.). | License from the Insurance Commissioner (O.C.G.A. Title 33, Chapter 64). |
| Key rules | Limits on steering patients to PBM-owned pharmacies and on clawbacks; network adequacy standards; annual PBM transparency reports (first due July 1, 2026). Spread pricing is to be studied rather than banned. | Spread pricing banned for insurers and their PBMs. | Medicaid has used a single state PBM since October 2022 (R.C. 5167.24). | A PBM may not require use of a pharmacy it or an affiliate owns, except for specialty drugs (§ 15-1611.1); rules on affiliate reimbursement and generic pricing lists. Medicaid managed care contracts bar spread pricing. | PBMs must charge state and local government plans the price paid to the pharmacy and must offer plans 100% rebate pass-through; they report payments 10% or more above or below national average acquisition cost. |
| 2025–26 changes | HB 2050 would bar PBMs from owning pharmacies; referred to House Health in November 2025 (as reported). On Oct. 13, 2026, the Attorney General sued insulin manufacturers Eli Lilly, Novo Nordisk and Sanofi and PBMs including Express Scripts, CVS Caremark and OptumRx in Commonwealth Court, alleging violations of the state's consumer protection law, civil conspiracy and unjust enrichment. The allegations have not been decided (as reported). | 2026: SB 669 and HB 830 require pass-through pricing and full rebate pass-through starting July 1, 2027. 2025: HB 2610 and SB 875 direct a single Medicaid PBM by July 1, 2026. | HB 229 (2026) PBM licensing; PBM provisions in the 2025 budget bill, HB 96 (as reported). | A 2025 PBM workgroup (Ch. 730) reports by Dec. 31, 2026. | HB 196 (2025) sets acquisition cost plus a dispensing fee for state employee plans from 2026 (as reported). SB 91, limiting state plan contracts with PBMs that own pharmacies, did not pass (as reported). |
| Drug prices | |||||
| Affordability board | None. No board bill found in the 2025–26 session; earlier bills were introduced in 2019–20 and 2021–22. | None. The legislature passed board bills in 2024, 2025 and 2026; each was vetoed (Gov. Youngkin in 2024 and 2025; Gov. Spanberger on May 19, 2026). | None. HB 890 (2026) would create a board with payment limits across payers; it is in the House Insurance Committee. | Yes, since 2019. It can set upper payment limits for state and local government purchasers; a 2025 law (Ch. 610/611) allows wider use once two limits have been in effect for a year. It has voted limits for Jardiance and Ozempic; governments may begin applying them Jan. 1, 2027 and must after Jan. 1, 2028. The regulations are not yet listed as final. | None. HB 931 (2026) proposed a board with payment limits and did not pass (as reported). |
| Manufacturer price reporting | No manufacturer price-reporting law. | Yes, since 2021 (Va. Code § 54.1-3442.02). Manufacturers report each year on brand drugs with a list price of $100 or more and price increases of 15% or more (generics: 200% or more). Filings are confidential (Va. Code § 32.1-23.4); aggregate data is public. | No manufacturer price-reporting law found. | No routine manufacturer price-increase reports; the affordability board identifies drugs for cost review using launch-price and price-increase thresholds. | No manufacturer price-reporting law found. |
| 340B discounts | |||||
| Contract pharmacy law | No law. HB 2797, introduced Sept. 29, 2026, addresses 340B reimbursement and distribution protections; it is in House Human Services. | No law. A 2024 bill (SB 119) was vetoed (as reported). A 2026 law (SB 278, Ch. 887) creates a 340B work group, with a report due Nov. 1, 2026. | No law; SB 198 and HB 276 are in committee. The 2025 budget added annual 340B reporting by covered entities (R.C. 3701.88). | Yes, 2024 (HB 1056, Ch. 962; effective July 1, 2024). Attorney General enforcement; $5,000 per package. A Fourth Circuit panel vacated the denial of a preliminary injunction and remanded in April 2026; the full court granted rehearing in late May, with no argument date confirmed. The law remains in effect (as reported). | No law. HB 139 (2025) would have barred manufacturer and wholesaler restrictions; it did not advance (as reported). |
| Sources | pa.govpa.govfastdemocracy.comattorneygeneral.govpenncapital-star.comwpxi.com | law.lis.virginia.govlaw.lis.virginia.govlaw.lis.virginia.govvpap.org | codes.ohio.govcodes.ohio.govcodes.ohio.govohiohouse.gov | insurance.maryland.govpdab.maryland.govmgaleg.maryland.govmgaleg.maryland.govca4.uscourts.gov | law.justia.comoci.georgia.govapp.azure.legiplex.compolicyrisk.com |
| Last updated | 2026-10-16 | 2026-10-15 | 2026-10-15 | 2026-10-15 | 2026-10-15 |
What stands out
PBM rules are converging, at different speeds
Every state licenses or registers PBMs, or will soon (Ohio's new license is required from July 2027), and states limit practices such as steering patients to PBM-owned pharmacies. Some states now regulate the pricing model itself: Virginia will require pass-through pricing and full rebate pass-through from 2027, while Pennsylvania's 2024 law orders a study of spread pricing.
Public plans go first
Ohio and Virginia use or are moving to a single Medicaid PBM, and Georgia set its pricing rules first for state and local government plans. States can set terms as purchasers before they set them as regulators.
Drug price authority is the dividing line
Maryland's board can cap what state and local government plans pay for a drug, with a path to wider use. Board bills were vetoed in Virginia, did not pass in Georgia, are pending in Ohio, and were not introduced in Pennsylvania this session.
340B is moving to the courts and to study
Maryland's contract pharmacy law is in effect while the full Fourth Circuit reconsiders a manufacturer challenge. Virginia created a work group, and Ohio required hospitals and clinics in the program to report how they use it.
Reporting is the most common tool
Where states have not set prices, they have asked for information: PBM transparency reports in Pennsylvania, manufacturer price reports in Virginia, payment reports in Georgia, and 340B reports in Ohio.
What to watch
- Pending: the full Fourth Circuit's rehearing of the challenge to Maryland's 340B contract pharmacy law (argument date not confirmed).
- November 1, 2026: Virginia's 340B work group report.
- December 31, 2026: Maryland's PBM workgroup report; Ohio's General Assembly session ends with HB 890 and the 340B bills in committee.
- January 1, 2027: State and local government purchasers may begin applying Maryland's first upper payment limits, for Jardiance and Ozempic, if the regulations are final; they must apply them after January 1, 2028.
- 2027 sessions: whether Virginia's legislature takes up an affordability board a fourth time, and whether Pennsylvania's HB 2797 on 340B moves.
- July 1, 2027: Virginia's pass-through pricing requirement and Ohio's PBM license requirement take effect.
The question I expect to shape the next cycle: whether states keep regulating the drug supply chain one link at a time, or start treating pricing across PBMs, manufacturers, and pharmacies as a single decision.
How this was compiled
Scope. Five states, three areas: pharmacy benefit manager regulation, drug price authority and reporting, and 340B contract pharmacy laws. Each cell describes enacted law first and notes notable 2025–26 bills separately.
Sources. Facts are drawn from statutes, session laws, legislative records, regulator and board pages, and court orders. Several legislature sites block automated access; where a bill's history comes from a site that copies official records, the source list links that copy. Where a detail rests on a secondary source, the table says "as reported." Where a detail could not be confirmed, the page says so rather than guessing.
Neutrality. Drug manufacturers, PBMs, insurers, pharmacies, hospitals, and patient groups all have stakes in these laws. This page describes what states have decided and how, not whether those decisions are right.
The underlying data is in state-drug-supply-chain.csv. This comparison is for policy analysis and is not legal or regulatory advice.