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Pharmacy Benefit Manager (PBM) Compliance and Enforcement

PBM Registration

"Pharmacy Benefit Manager" means any entity doing business in this state that administers or manages prescription drug benefits, including claims processing services and other prescription drug or device services as defined in section 10-16-122.1, on behalf of any carrier that provides prescription drug benefits to residents of this state, either pursuant to a contract with the carrier or as an entity that is related to, associated by common or other ownership with, or otherwise associated with the carrier (C.R.S.10-16-102(49)).

A PBM does not include:

  • A health-care facility licensed or certified by the department of public health and environment pursuant to section 25-1.5-103 (1)(a);
  • A provider;
  • A consultant who only provides advice as to the selection or performance of a pharmacy benefit management firm; or
  • A nonprofit health maintenance organization that offers managed care plans that provide a majority of covered professional services through a single, contracted medical group and that operates its own pharmacies (C.R.S.10-16-102(49)(b)).

Colorado's House Bill (HB) 23-1227 introduced new obligations for all Pharmacy Benefit Managers (PBMs) doing business in Colorado to register annually with the Colorado Division of Insurance (DOI). Colorado Regulation 4-2-97 outlines a registration deadline of 7/1/2024 and provides guidance on the form and manner for PBMs to register with the DOI including required documentation. 

PBM Registration Instructions

Colorado's PBM application is hosted through sircon.com/colorado. The DOI will process complete applications only, which includes submitting application form, attaching applicant's organizational and financial documents, completing the attestation, and paying the filing fee in Sircon. 

1. Begin Application

To apply for a PBM registration, click the button below. 

PBM Registration Application 

Next, click “Apply for a License” > “Other Insurance & Non-Insurance Licenses” > Select if you are "Resident/Non-Resident" > Select "Firm" from "Individual/Firm".

Note: If the application is requiring a resident license number and you do not have one, you may enter "00000" to continue. 

2. Attach Documentation

The following state-specific documents must be submitted with the application. Documents may be uploaded using the "Upload Documents for Required Items" page at the end of the application.

State-Specific Required Application Materials

PBM Organizational Documents

  • Articles of Incorporation, Articles of Association, and partnership agreements of the PBM;
  • A copy of all by-laws or similar documents regulating the conduct or the internal affairs of the PBM; and
  • Relevant documentation (policies and procedures) and a detailed explanation that demonstrates the PBM has adopted processes to ensure compliance with the requirements in sections 10-16-122.1, 10-16-122.3, 10-16- 122.4, 10-16-122.5, 10-16-122.6, 10-16-122.7, and 10-16-122.9, C.R.S, including any written policies or procedures describing the appeals or dispute resolution processes between the PBM and a PBM-affiliated pharmacy, as applicable.

Financial and Other Documents

  • The most recent year-end financial statement for the PBM;
  • A listing of all carriers with which the PBM is contracted to provide pharmacy benefit services in Colorado, including any non-ERISA self-funded or governmental plans;
  • The number of projected enrollees or beneficiaries in Colorado to be serviced by the applicant during the upcoming year for all contracted insurers; and
  • A listing of any delegated or contracted companies that perform part of the PBM's services. 

3. Submit Filing Fee

PBMs are required to provide a $2,500 non-refundable filing fee for all initial and renewal applications. Payment must be collected as part of the application.

Who to Contact for Help

For assistance using Sircon.com, please refer to the "Help" and "FAQ" pages on Sircon.com for information and how-to guides. You may also call Sircon Support at 1-877-846-4430, or request assistance by selecting the "Open a Case" link at the bottom of the website.  

For all other questions, please contact the Division of Insurance, PBM Enforcement Section at dora_pbm_compliance@state.co.us.

Licensing Inquiries

To streamline the licensing process, we have provided instructions on printing a license, locating your license number, and finding your license expiration date using Sircon.

Print a License

To print your license, log into your Sircon account for the Colorado Department of Regulatory Agencies account and navigate to the "Print a License" section under the "Licenses" section. Select "Print a license" and follow the on-screen instructions. 

Locating Your License Number

Your license number or National Producer Number (NPN) can be found on the Sircon website for the Colorado Department of Regulatory Agencies by selecting "Look up My License Number / NPN" under the Licenses section. If you do not have a Sircon account, you can use the public "License Inquiry Service" under the "Consumers" section.
 

Finding Your License Expiration Date

Log into Sircon for the Colorado Department of Regulatory Agencies and access your license details to check your expiration date. You can also track your renewal status by selecting "Check Status of a License Application or Renewal."
 

The Colorado Division of Insurance (DOI) has authority to enforce statutory requirements regarding Pharmacy Benefit Management Firms (PBMs), as granted by House Bill (HB) 23-1227 Enforce Laws Against Pharmacy Benefit Managers. The DOI assists individuals and pharmacies with concerns related to PBM business practices and conduct that may be in violation of state law. If you if have an issue you would like to submit to the DOI, please review the information outlined below.