PBM Reporting

Effective November 1, 2023, the Oklahoma Office of the Attorney General has enforcement authority under the provisions of the Patient's Right to Pharmacy Choice Act, 36 O.S. §§ 6958-6971. 

Section 6962 Quarterly Reports

The Act requires each Pharmacy Benefit Manager (PBM) operating in the State to report on a quarterly basis, for each health insurer payor, the following information:     

1. the aggregate amount of rebates received by the PBM,
2. the aggregate amount of rebates distributed to the appropriate health insurer payor,
3. the aggregate amount of rebates passed on to the enrollees of each health insurer payor at the point of sale that reduced the applicable deductible, copayment, coinsure or other cost sharing amount of the enrollee,
4. the individual and aggregate amount paid by the health insurer payor to the PBM for pharmacy services itemized by pharmacy, drug product and service provided, and
5. the individual and aggregate amount a PBM paid a provider for pharmacy services itemized by pharmacy, drug product and service provided.

36 O.S. § 6962(D)(5)

Reporting should be submitted using the template provided below. Please make no changes to the format of the template and be careful to complete both tabs included. The report should be submitted in MS Excel (.xlsx) or CSV format and emailed to [email protected]. To ensure all rebates and post-adjudication adjustments have been made to the claims reporting, the AG’s office has agreed to extend the due dates by a full year. Reports should be submitted no later than 1 year after the end of the reported period. (see schedule below)

Click here to download the required template for your PBM's Section 6962 Quarterly Report.

Each report submission must be accompanied by a general attestation of authenticity (see below) signed by the representative of the PBM who prepares the report.

Attestation Example: “In compliance with Title 36 O.S. §§ 6958 - 6968, the Oklahoma Pharmacy Benefits Manager Quarterly Rebate Report herein attached is submitted to be filed with the Oklahoma Office of the Attorney General on behalf of [PBM legal name]. I hereby attest to the accuracy of the data and facts represented within this document as of [Date submitted].”

Any PBM who fails to comply with reporting requirements is subject to disciplinary action for violation of the Act and may be subject to license censure, suspension, revocation, and/or civil fines up to a maximum of $10,000. 36 O.S. § 6966.1(B)(1-2).

Network Access Adequacy Standards

The Patient’s Right to Pharmacy Choice Act, Title 36 O.S.§§ 6958 – 6968, requires pharmacy benefits managers (“PBMs”) doing business in the State of Oklahoma to comply with certain pharmacy network adequacy standards. The Oklahoma Office of the Attorney General (“OAG”) is required by the Act to review and approve retail pharmacy network access for all Oklahoma-licensed PBMs. 36 O.S.§§ 6962. These reviews will be completed semi-annually.

Each PBM licensed in the State of Oklahoma is required to submit its “Oklahoma Pharmacy Benefits Manager Retail Pharmacy Network Access Report” to the OAG no later than 45 days following the end of the 2nd and 4th quarter of each calendar year (see schedule below). Such a report shall detail the PBM’s retail pharmacy networks and the access provided to covered individuals under Title 36 O.S. § 6961(A).

In addition, the OAG requires all Oklahoma licensed PBMs to provide notice before making any significant retail pharmacy network change that may impact Oklahoma consumer access to a retail pharmacy network within their corresponding access standard area(s) as required by the Act. 36 O.S. § 6961. This may include but is not limited to, any mergers or acquisitions.

Every Oklahoma Pharmacy Benefits Manager Retail Pharmacy Network Access Report is submitted using the attached template in MS Excel format that is searchable and in a manner that allows for the data to be arranged and organized. The report should include no redaction, encryption, or password protection. Please make no changes to the format of the template. The MS Excel file should be named with the following convention that identifies the PBM’s Oklahoma License number, the year, the semi-annual period included, and the report’s description (see example below).

Click here to download the required template for your PBM's Network Access Report

The Oklahoma Pharmacy Benefits Manager Retail Pharmacy Network Access Report is organized into multiple sheets (or tabs) for submission of the required information. Please ensure that each of the following sheets is accurately completed.

1. PBM Affiliations;
2. Geo Access Report Summary; On this sheet the PBM will list all of its pharmacy networks by name and type (retail or preferred) and provide the other information as indicated;
3. For each of its networks, the PBM will fill out the following three (3) sheets, renaming such sheets as appropriate, and adding additional sheets as needed in the same format:

• Network A – Retail Pharmacies (or Preferred Pharmacies)
• Network A – Retail Dot Map (or Preferred Rx Dot Map)
• Network A – Retail Rx Adequacy (or Preferred Rx Adequacy)

Each report submission must be accompanied by a general attestation of authenticity (see below) signed by the representative of the PBM who prepares the report.

Attestation Example: “In compliance with Title 36 O.S. §§ 6958 - 6968, the Oklahoma Pharmacy Benefits Manager Retail Pharmacy Network Access Report herein attached is submitted to be filed with the Oklahoma Office of the Attorney General on behalf of [PBM legal name]. I hereby attest to the accuracy of the data and facts represented within this document as of [Date submitted].”

Reports should be submitted electronically to [email protected]. Thank you in advance for your assistance and timely response. Failure to timely submit any reports is considered a violation and subject to disciplinary action under 36 O.S. § 6966.1(B).

If you are a representative of a Pharmacy Benefits Manager with any questions or concerns regarding your reporting requirements, please do not hesitate to email us at [email protected]. If you are a pharmacist or a patient and feel you have been a victim of a violation of the Patient's Right to Pharmacy Choice Act, please return to the previous page to submit a complaint. 

Patients & Consumers

• Patient’s Right to Pharmacy Choice Act
• Pharmacy Audit Integrity Act
• Pharmacy Benefit Plans

Complaint Forms

• Patient & Consumers
• Pharmacist & Pharmacy
• PSAO

Pharmacy Benefits Managers

• Reporting Requirements
• FAQs
• Section 6962 Quarterly Report Template
• Network Access Adequacy Standards Template