CVS · 10-Q · 2026Q3 · Full report

PBM Legislative Restrictions

CVS HEALTH Corp · 2026-11-04 · Importance 35 · Surprise 24

The filing reports that legislation and regulations seeking comprehensive regulation of pharmacy benefit manager activities have been proposed or enacted in a majority of U.S. states and at the federal level. Some states have recently enacted or are considering laws prohibiting pharmacy licensure for pharmacies affiliated with a PBM. CVS Health says these measures could constrain commercially reasonable operations, standardization of PBM products and services across state lines, and its ability to provide pharmacy and PBM services within the same state.

Key facts

• PBM regulation legislation or regulations have been proposed or enacted in most states and federally; some states have enacted or are considering restrictions on pharmacy licensure for pharmacies affiliated with a PBM. source
• PBM legislative and regulatory activity could impair CVS Health's ability to operate on commercially reasonable terms, standardize products and services across state lines, or provide pharmacy and PBM services in the same state. source