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Home » Bulletins » Colorado Enforces Stronger Oversight of Pharmacy Benefit Managers With Updated 2025 Regulation

Colorado Enforces Stronger Oversight of Pharmacy Benefit Managers With Updated 2025 Regulation

CO| Colorado’s Amended Regulation 4-2-97 establishes comprehensive annual registration and compliance requirements for pharmacy benefit managers (PBMs) operating in Colorado, including detailed application procedures, disclosure obligations, and enforcement mechanisms. Effective November 15, 2025, all PBMs must provide organizational, officer, and compliance information during both initial and renewal registrations and pay a $2,500 fee; they must also attest under penalty of perjury to the truth and completeness of their submissions. The regulation details disciplinary actions, confidentiality provisions, and allows PBMs with fewer than 100 covered individuals to request documentation exceptions, ensuring regulatory oversight and public transparency for PBM activities in the state.

Key Points:

  • PBMs must register annually, submit detailed application materials (including company documents, compliance policies, and financials), and pay a $2,500 fee before doing business in Colorado.
  • The regulation enforces strict attestation and disclosure requirements, provides for sanctions (such as suspension or revocation), and clarifies the treatment of confidential information under the Colorado Open Records Act.
  • PBMs with fewer than 100 covered individuals may request exceptions to certain documentation requirements, subject to approval and explanation.

Click here to see CO Amended Regulation 4-2-97

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