PBM oversight

Tennessee FAIR Rx Act Targets Pharmacy-Insurer-PBM Ownership

Tennessee’s final FAIR Rx Act is narrower than early drafts, but it still targets the pharmacy-insurer-PBM stack. CVS is suing to block the law before its July 2028 trigger.

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TL;DR:
Tennessee’s final FAIR Rx Act targets companies that combine pharmacy, insurer, and PBM control. CVS is challenging the law, but its legal and operational impact claims remain allegations.

What you need to know

The change: Tennessee’s final FAIR Rx Act targets the combined ownership or control of a pharmacy, a health insurance issuer, and a PBM. (SA0841)
Who is affected: The law is most relevant to vertically integrated healthcare companies that connect pharmacy operations, health insurance, and PBM functions under common ownership or control. (SA0841)
Why it matters: The final law is not a simple PBM-pharmacy ownership ban. It is a structural limit on the pharmacy-insurer-PBM stack. (Tennessee General Assembly SB2040)
What to do first: Identify any Tennessee pharmacy operations connected to an entity or affiliate that also owns, operates, controls, or directs both a health insurance issuer and a PBM. (SA0841)
Key date or trigger: The final amended restriction applies on and after July 1, 2028. (SA1052)

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