Florida pharmacies just got a new layer of protection against pharmacy benefit managers, and it’s already the law. Under the new Florida PBM law 2026 — officially the Drug Prices and Coverage Act (CS/HB 697) — Governor DeSantis signed the legislation on March 24, 2026, and it took effect July 1, 2026. If you own or operate a pharmacy in Florida, this law changes what your PBM contracts can require of you, and it’s worth understanding before your next contract renewal, audit, or reimbursement dispute.

What the Law Actually Does

The Drug Prices and Coverage Act builds on Florida’s 2023 Prescription Drug Reform Act, tightening the rules around how PBMs deal with the pharmacies in their networks. Three changes matter most:

No more below-cost dispensing mandates. PBMs can no longer require a pharmacy to dispense a prescription drug or biological product for less than the pharmacy’s actual acquisition cost. This has been one of the most common complaints from independent pharmacies for years — reimbursement rates that don’t even cover what the pharmacy paid for the drug. That practice is now off the table.

Affiliate pricing parity. PBMs that also own or are affiliated with pharmacies can no longer reimburse those affiliated pharmacies at a higher rate than they pay non-affiliated, independent pharmacies for the same drugs and services. This addresses a long-standing concern that vertically integrated PBM-pharmacy conglomerates were using their own reimbursement structure to squeeze out independent competitors.

Streamlined appeals. Pharmacies can now submit a single, consolidated administrative appeal covering multiple claims involving the same drug dispensed during the same month, instead of filing separate appeals for every individual claim. For a busy pharmacy disputing a batch of underpayments, this alone can save significant time and cost.

The Act also narrows the definition of a “pharmacy benefits plan or program” to exclude plans that exclusively serve PACE organizations (Programs of All-Inclusive Care for the Elderly).

How This Differs From the 2023 Prescription Drug Reform Act

Florida pharmacies may remember the 2023 Prescription Drug Reform Act, which first required PBMs to use pass-through pricing, disclose affiliated organizations, and offer a reasonable administrative appeal process. That law also barred financial clawbacks tied to performance measures or erroneous claims and required PBMs to obtain a license as an insurance administrator.

The 2026 Drug Prices and Coverage Act doesn’t replace that framework, it sharpens it. Where the 2023 Act set up general fairness and transparency requirements, the 2026 Act closes specific loopholes that pharmacies and their counsel identified over the past three years:

• The 2023 Act discouraged favoritism toward affiliated pharmacies in general terms. The 2026 Act makes the prohibition explicit and numeric: an affiliated pharmacy cannot be paid more than a non-affiliated pharmacy for the same drug or service.
• The 2023 Act didn’t directly address below-cost dispensing. The 2026 Act closes that gap outright.
• The 2023 Act allowed appeals but didn’t specify how multiple claims should be handled. The 2026 Act now permits pharmacies to consolidate claims involving the same drug and dispensing period into a single appeal.

In short, if your pharmacy has been managing PBM relationships under the assumption that the 2023 rules were the final word, the 2026 Act is a reminder that Florida’s PBM oversight is a moving target, not a settled framework.

Why This Matters Beyond Compliance

This law didn’t come out of nowhere. Florida lawmakers have been building out PBM regulation since the 2023 Prescription Drug Reform Act first required pass-through pricing and barred PBMs from favoring their own affiliated pharmacies. The 2026 session pushed further: alongside the Drug Prices and Coverage Act, legislators introduced companion measures aimed at international reference pricing for prescription drugs and broader PBM oversight, and the same session created a new licensure pathway for naturopathic doctors and specialty licensing for memory-care assisted living facilities. Taken together, it’s a signal that Tallahassee has an appetite for reshaping how healthcare businesses and PBMs operate, not just a one-time fix.

For pharmacies, that means this year’s changes are likely a floor, not a ceiling. If your pharmacy has felt like PBM contracts were a take-it-or-leave-it proposition, that dynamic is shifting, at least on paper. Whether it shifts in practice depends on how carefully pharmacies review their existing agreements now and how aggressively they use the new appeal and reimbursement protections going forward, because a law on the books only helps the businesses that actually enforce it.

Rulemaking and Enforcement: What Comes Next

The Drug Prices and Coverage Act doesn’t just create new obligations, it also strengthens the state’s ability to act on them. As with the 2023 Act, oversight of PBM licensing and conduct in Florida runs primarily through the Office of Insurance Regulation (OIR) and the Department of Financial Services (DFS), which have authority to examine and investigate PBMs suspected of violating state law.

A few things pharmacies should watch for over the coming months:

Implementing rules. DFS and OIR are expected to issue formal rules and guidance clarifying how the Act’s provisions will be interpreted and enforced. These rules typically go through a public comment period, and pharmacies or their trade associations can weigh in before the rules are finalized.

Investigations and audits. PBMs found to be out of compliance can face examination and investigation by state regulators. Pharmacies that have documented instances of below-cost dispensing demands or affiliate favoritism will be in a far stronger position to support a complaint or investigation than those relying on memory or informal records.

No private right of action yet established. As with much of Florida’s existing PBM regulation, enforcement primarily flows through state regulators rather than direct pharmacy-versus-PBM litigation. That makes documentation and, where appropriate, formal complaints to DFS or OIR the most direct path to relief, alongside the administrative appeal process built into the Act itself.

Pharmacies shouldn’t wait for a rule to be finalized or an investigation to be announced before taking their own contracts seriously. The clearest path to benefiting from this law is proactive: know what your contract says, know what the law now prohibits, and be ready to document the gap between the two.

What Pharmacies Should Do Now

Review existing PBM contracts. Any agreement executed, renewed, or amended going forward needs to reflect the new requirements. If your contract still contains language allowing below-cost dispensing mandates or doesn’t address affiliate reimbursement parity, it may already be out of step with the law.

Audit recent reimbursements. If you suspect you’ve been paid less than an affiliated pharmacy for the same drug, or reimbursed below acquisition cost, this is the moment to start documenting it. The consolidated appeal process makes it easier to challenge a pattern of underpayment rather than fighting claim by claim.

Watch for implementing rules. The Florida Department of Financial Services and Office of Insurance Regulation are expected to issue rules and guidance to implement the Act. Pharmacies that get ahead of this — rather than waiting for an enforcement action — will be in a much stronger position.

Don’t assume your PBM has already complied. Contract language doesn’t update itself. If your PBM hasn’t proactively reached out with amended terms, that’s a conversation worth having, ideally with legal counsel reviewing the redlines before you sign anything.

Pharmacies have spent years absorbing reimbursement terms they had little real power to negotiate. This law gives independent pharmacies concrete grounds to push back, but only if they know their contract language well enough to spot a violation when they see one.

Frequently Asked Questions

When did Florida’s new PBM law take effect? The Drug Prices and Coverage Act (CS/HB 697) was signed on March 24, 2026, and took effect July 1, 2026.

Does this law apply to PBM contracts signed before July 1, 2026? Existing contracts should be reviewed against the new requirements. Any agreement executed, renewed, or amended after the effective date needs to reflect the Act’s provisions, and pharmacies should not assume older contract language remains enforceable if it conflicts with the new law.

Can a PBM still require below-cost dispensing under any circumstances? No. The Act prohibits PBMs from requiring a pharmacy to dispense a prescription drug or biological product for less than the pharmacy’s actual acquisition cost, with no carve-out for special circumstances written into the law.

What should a pharmacy do if it believes a PBM is violating the law? Document the specific claims, dates, and reimbursement amounts involved, then consider both the Act’s consolidated administrative appeal process and, where appropriate, a formal complaint to the Florida Office of Insurance Regulation or Department of Financial Services. Legal counsel can help determine which path fits the situation.

Is this the last PBM law Florida is likely to pass? Unlikely. Florida has passed PBM-related legislation in 2023 and again in 2026, and lawmakers introduced additional PBM and drug-pricing bills this session that didn’t pass. Pharmacies should expect continued legislative activity in this area.

The Bottom Line

The Florida PBM law 2026 — the Drug Prices and Coverage Act — gives Florida pharmacies real, enforceable leverage against practices that have squeezed margins for years. But leverage only helps if it’s used. Pharmacies that review their contracts, document reimbursement patterns, and understand exactly what PBMs can no longer require are the ones who will actually benefit from this law, not just read about it.

If you have questions about how the Drug Prices and Coverage Act affects your pharmacy’s PBM contracts, or you need a contract reviewed before you sign, our pharmacy law team is here to help.