LA| Advisory Letter 2025-05 from the Louisiana Department of Insurance informs all licensed pharmacy benefit managers (PBMs) and health insurers contracting with PBMs about new reimbursement requirements under Act 474, codified at La. R.S. 22:1868, effective January 1, 2026. PBMs must use NADAC as the prescription drug pricing benchmark (or an approved alternative with equal or better claim payment accuracy), apply an adjustment factor (markup) designed to limit claim payment errors to no more than two percent per drug, and include a professional dispensing fee as part of the reimbursement formula.
For 2026, LDI recommends a 2% markup, to be adjusted after any quarter in which more than 2% of paid claims are later corrected, and allows the markup to be applied either as a percentage or a flat increase so long as it yields an aggregate 2% markup. The professional dispensing fee cannot be zero or merely nominal and must be reasonably set based on prevailing industry practices to compensate for the professional services component of dispensing.