North Dakota Insurance Department · October 29, 2026 · Primary source
25 pharmacy benefit managers notified to comply in North Dakota
What the document says
On October 29, 2026, North Dakota Insurance Commissioner Jon Godfread issued notices to 25 pharmacy benefit managers citing apparent unlicensed operation within the state. Each notified PBM has 20 days from receipt of the notice to submit a complete license application to the North Dakota Insurance and Securities Department before a cease-and-desist order is issued. PBMs that submit a complete application within the 20-day window will have their applications processed in the ordinary course, and the Department will not issue a cease-and-desist order. PBMs that fail to apply within the period face cease-and-desist orders as well as further penalties and fines. The enforcement action follows the passage of North Dakota House Bill 1584 during the 2025 Legislative Assembly. That legislation established a dedicated PBM Division within the Department and expanded the Commissioner's authority to investigate and enforce state laws governing PBM practices. Licensing is described by the Department as a key component of its PBM oversight framework. The Department states it will continue to review PBM compliance and use its enforcement authority to protect North Dakota consumers, with the 25 notices framed as an initial voluntary-compliance opportunity before escalated enforcement steps.
What this may mean
Applies to all PBMs operating in North Dakota without a state license, placing them at immediate risk of cease-and-desist orders and additional fines if a complete license application is not submitted within 20 days of notice receipt. PBMs currently serving North Dakota insurers, pharmacies, or plan members are subject to the Department's expanded investigative and enforcement authority under House Bill 1584.
Informational only. Not legal, medical, financial, or other professional advice. Always consult a qualified professional familiar with your specific facts before relying on any item.
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