What you need to know

Prime Therapeutics (Prime) recently communicated that on June 11, 2025, the Governor of Iowa signed Senate File (SF) 383 into law, introducing provisions affecting pharmacy reimbursement and imposing regulations on plan sponsors through oversight of pharmacy benefit managers (PBMs).  

However, on July 21, 2025, a federal court in Iowa issued a preliminary injunction preventing many aspects of the law from taking effect. The lead plaintiff, the Iowa Association of Business and Industry (ABI), has requested its employer members in Iowa to identify the PBMs and other entities administering their benefits. 

Overview

Summary of Iowa SF 383 Requirements 
SF 383 requires PBMs to pay Iowa retail pharmacies at least the National Average Drug Acquisition Cost (NADAC), or Wholesale Acquisition Cost (WAC) if NADAC isn’t available, plus a $10.68 professional fee. The law also introduced rules about benefit design, cost sharing, network setup and related requirements. 

Court Injunction and Impact 
On July 21, 2025, a federal court issued a preliminary injunction that stops many parts of the law from taking effect for ABI and other employers who sponsor plans under the Employee Retirement Income Security Act (ERISA), as well as their contractors and agents, including PBMs. The blocked rules include the NADAC reimbursement and other benefit design requirements. 

Specific ABI Member Actions 
ABI, as a trade group, was asked by the court to list all companies and agents who administer benefits for its employer members to ensure they are covered by the injunction and shielded from enforcement of the enjoined provisions.  

If your organization belongs to ABI, you should have received an email from ABI about the lawsuit with a request to fill out their administrator identification form, including your PBM.  

ACTION: If you are an ABI member, please make sure that you have identified Prime as your PBM (which may be in addition to your third-party administrator). If you are a member who did not complete the form — whether due to not receiving the email or missing the original deadline — you are encouraged to submit your information as soon as possible, including Prime as your PBM. In either scenario, we ask that you notify Prime by sending an email to the Regulatory Change Management team.

Next steps

We will continue to monitor the lawsuit and any others, as well as any implementation guidance, and provide updates as they become available.

Questions

Please reach out to your Prime client account team representative to discuss how this may affect your specific services.