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New York Expands Regulation of Pharmacy Benefit Managers While ERISA Preemption Remains Uncertain
Locke Lord 
[Guidance Overview] Nov. 10, 2023 "PBMs operating in New York State must be licensed by DFS by January 1, 2024.... The new provisions significantly increase documentary and informational materials PBMs must submit to [the Department of Financial Services (DFS)], such as contracts, financials, governance, and ownership structure. Companies applying for licensure must also certify their compliance with DFS's cybersecurity regulation." |
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