Arkansas Rule 128 reporting requirements - Prime Therapeutics
Arkansas Rule 128 reporting requirements
What you need to know
The Arkansas Pharmacy Benefit Manager Licensure Act provides for the regulation of pharmacy benefit managers (PBMs) operating in the State of Arkansas. In 2024, the Arkansas Insurance Department (AID) released regulations and guidance pertaining to pharmacy reimbursement practices and data reporting to the AID.
Action required by June 16, 2025:
If your plan does not want Prime to provide reporting to the AID, please contact ClientCommunications@PrimeTherapeutics.com by June 16, 2025.
Reporting requirements
The data requested by the AID is limited to claims processed by Arkansas-licensed pharmacies. According to the AID, the reporting requirements are applicable to “all client types", which includes both insured and self-funded business.
The AID has released two reporting templates, one covering plans with 5,000 or more Arkansas residents, and the other covering plans with fewer than 5,000 Arkansas residents.
Prime Therapeutics (Prime) recognizes that the Arkansas law and the AID’s requirements raise significant questions, including the extent to which a state may regulate or compel reporting from or relating to:
Insured business written in other states
ERISA-governed plans
Self-funded non-ERISA plans from other states (e.g., a municipality in California)
Prime's approach
Prime’s understanding is that the AID believes it is entitled to collect this information and expects data with respect to “all client types”. Accordingly, we propose including all funding types in our reporting for your plans. Bulletin #18-2024 indicates that PBMs may file the reporting on behalf of its plan customers.
Next steps
We believe our approach is a reasonable one that should satisfy the AID at this time. You do not need to take any action at this time if you generally agree with our approach.
The AID has clarified that the latest reporting deadline has been extended to July 31, 2025 and is to include data from Jan. 1, 2025 – June 30, 2025.
Questions
Reach out to your account team representative.