Health Plans, Mid-market Accounts, National Accounts

Update: Tennessee market conduct examination

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Impacted: Clients with members who filled prescriptions in Tennessee in 2025

What you need to know

Prime has received notice of a scheduled audit by the Tennessee Department of Commerce and Insurance (TDCI) pursuant to Tenn. Code Ann. § 56-7-3101(b)(1)(A) and Tenn. Comp. R. & Regs. 0780-01-95-.11. As a licensed Pharmacy Benefit Manager (PBM), Prime is periodically reviewed by state regulators to ensure compliance with applicable laws and regulations. The audit will cover the period from Jan. 1, 2025 – Dec. 31, 2025, and will focus on Prime’s overall compliance with Tennessee PBM requirements.

The audit requires PBMs to provide TDCI with access to all records and files that are needed to complete the audit. Specifically, auditors have directed Prime to submit claims data for claims processed by Tennessee pharmacies for Tennessee residents, regardless of where the plan is issued. Tennessee laws that apply to this audit address confidentiality of information obtained or produced for TDCI. Importantly, information reviewed during the audit is treated as confidential by the state and not subject to public disclosure.

Final audit findings, which may be made public once the audit is complete, would be related to Prime’s overall performance as a PBM under Tennessee law and do not involve the disclosure of specific data.

For awareness only, no action is required from you.

Questions
Please contact your Prime account representative.