Pharmacy Benefit Manager Licensing

Pharmacy Benefit Manager (PBM) Licensing

The North Carolina Department of Insurance will begin licensing Pharmacy Benefit Managers (PBM) effective December 1, 2025, as required by North Carolina Senate Bill 257. These changes promote pricing transparency for patients and establish standards and criteria for the regulation and licensure of PBMs providing services for Health Benefit Plans in North Carolina as defined in NCGS 58-56A-1(3).

PBM Licensing Requirements

A Pharmacy Benefit Manger or PBM is defined by NCGS 58-56A-1(14) “An entity who contracts with a pharmacy on behalf of an insurer or third-party administrator to administer or manage prescription drug benefits to perform any of the following functions:

Negotiating rebates with manufacturers for drugs paid for or procured as described in this Article.
Processing claims for prescription drugs or medical supplies or providing retail network management for pharmacies or pharmacists.
Paying pharmacies or pharmacists for prescription drugs or medical supplies.

Note, a PBM that contracts only with single employer ERISA self-funded health plans must register as a TPA, as required by NCGS 58-56-51(f). Registration instructions and forms are found in our TPA website here: Registration Instructions.

PBM Licensing Forms and Instructions

All PBM license applications, notice of change of ownership, and/or change of officer or directors must be submitted electronically to LHinbox@ncdoi.gov or Citrix Sharefile, or other secure electronic filing method, no zip files. Payment of filing fees must be made separately via USPS or overnight at addresses shown below. Please include a copy of the cover letter with the check, in order that payment may be attributed accurately. Paper filings or notifications will not be accepted for the immediate future.

Checks can be mailed via USPS to:
NC Dept. of Insurance/L&H Division 3rd Floor
1201 Mail Service Center
Raleigh, NC 27699-1201

Checks can be mailed overnight to:
NC Dept. of Insurance/L&H Division
3200 Beechleaf Ct. 3rd Floor
Raleigh, NC 27604

Initial PBM License Application

All PBM license application documentation, notice of change of ownership, and/or change of officer or directors must be submitted electronically using Citrix ShareFile Instructions and Citrix ShareFile Instructions for TPA license applications or via email to LHinbox@ncdoi.gov, or other secure electronic filing method, no zip files. Initial Payment of filing fee of $2,000 must be done separately via USPS or overnight at addresses provided in the Filing Instructions below. Please include a copy of the cover letter in order that payment may be attributed accurately. Paper filings or notifications will not be accepted. See below for information required regarding Initial PBM License Application.

PBM Transmittal Form: Transmittal Form
PBM Application Form: Application Form
PBM Questionnaire Form: Questionnaire Form
List of PBM principal officials’ names and position along with the current email of the Compliance person. See the PBM Transmittal Form for what is to be included in the list.
Bios for Principal Officers: Biographical Affidavit Form
Power of Attorney Form: Power of Attorney Form for Company or Power of Attorney form for LLC
Company’s By-Laws
If the PBM contracts with insurers, provide a list of the insurers along with the insurer’s contact information.
Organizational documents such as articles of incorporation or organization, or other applicable documents, including all amendments made to the documents.
Financial statements for the last two fiscal years, prepared by an independent CPA
Narrative discussing internal controls of PBM operations: Internal Control Form
General description of business operations
Non-Refundable $2,000 filing fee
Current authorization to act on behalf of PBM, if PBM license application is being made by a third party filer.

Please contact Life & Health Division at LHinbox@ncdoi.gov with any questions.

TPA Registration

Please contact the Life and Health general mailbox at LHinbox@ncdoi.gov with any questions.

Renewal PBM License Application

All PBM license application documentation, notice of change of ownership, and/or change of officer or directors must be submitted electronically using Citrix ShareFile Instructions and Citrix ShareFile Instructions for TPA license applications or via email to LHinbox@ncdoi.gov, or other secure electronic filing method, NO ZIP FILES. Renewal filing fee of $1,500.00 must be paid separately via USPS or overnight at addresses provided in the Filing Instructions below. Please include a copy of the cover letter in order that payment may be attributed accurately. Paper filings or notifications will not be accepted. See below for information required regarding Renewal PBM License Application.

PBM Transmittal Form: Transmittal Form
PBM Application Form: Application Form
PBM Questionnaire Form: Questionnaire Form
List of PBM principal officials’ names and position along with the current email of the Compliance person. See the PBM Transmittal Form for what is to be included in the list.
Bios for Principal Officers: Biographical Affidavit Form
Power of Attorney Form: Power of Attorney Form for Company or Power of Attorney form for LLC
Company’s By-Laws if there is a change from the Initial application
If the PBM contracts with insurers, provide a list of the insurers along with the insurer’s contact information.
Organizational documents such as articles of incorporation or organization, or other applicable documents, including all amendments made to the documents.
Financial statements for the last two fiscal years, prepared by an independent CPA
Narrative discussing internal controls of PBM operations: Internal Control Form
General description of business operations
Non-Refundable $1,500 filing fee
Current authorization to act on behalf of PBM, if PBM license application is being made by a third-party filer.

Please contact the Life and Health general mailbox at LHinbox@ncdoi.gov with any questions.

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