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California SB41 Holds PBMs to Fiduciary and Transparency Standards
Davis Wright Tremaine LLP 
[Guidance Overview] Nov. 3, 2025 "SB 41 goes beyond federal pricing transparency reforms by imposing an explicit fiduciary duty on PBMs to act in the best interests of their payer clients, which include both self-insured and fully insured ERISA health plans. The law also prohibits spread pricing, mandates pass-through rebates, requires state licensure, and introduces comprehensive disclosure obligations. Collectively, these provisions mark a fundamental shift in PBM accountability and create new compliance priorities for health plan sponsors, insurers, and other payers in California." MORE >> |
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