Effective July 1, 2023 the Florida legislation reshapes the PBM landscape, requiring that PBMs pass through 100% of all manufacturer rebates to plan sponsors, while prohibiting spread pricing, clawbacks, mail order mandates, affiliate-only networks, and other practices that have long been status quo for many in the pharmacy industry.

Florida SB 1550 requires that entities in Florida with a PBM service contract executed on or after July 1, 2023, including a renewal, are required to be pass-through as of January 1, 2024. That may be a challenge for PBMs not accustomed to crediting plan sponsors.

Employee Benefit Advisors is uniquely qualified to help transition companies to meet the new regulatory requirements. We have extensive experience in working with total pass through PBMs and reduced the pharmacy spend for our clients. Contact us for all your compliance questions.


Employee Benefit Advisors provides employee benefits, tax-advantaged healthcare, compliance guidance for ACA and Health & Welfare DOL Audits, and PEO Advisory & Consulting Services.