ARTICLE
28 January 2026

Understanding California SB-41: What PBMs Operating In California Need To Know

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Member Theresa Carnegie, Associate Hassan Shaikh, and Law Clerk Grace Callander wrote an article published by the Employee Benefit Plan Review focused on the key provisions of a set of new regulations for PBMs and health plans operating in California, including requirements related to governance and oversight, transparency and pricing, and enforcement.
United States Employment and HR
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Member Theresa Carnegie, Associate Hassan Shaikh, and Law Clerk Grace Callander wrote an article published by the Employee Benefit Plan Review focused on the key provisions of a set of new regulations for PBMs and health plans operating in California, including requirements related to governance and oversight, transparency and pricing, and enforcement.

The authors write,"SB-41 introduces new contractual and operational requirements that will require most PBMs active in the state to adjust their existing financial and contractual relationships. The law contains many requirements similar to existing PBM regulation in other states, however, SB-41's requirements related to PBM compensation are novel at the state level."

Source

Employee Benefit Plan

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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