Pharmacy Benefit Manager (PBM) Registration and Compliance


PBM Registration Overview

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 Definition

"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)).

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.


Stakeholder Meetings

The Division hosted a stakeholder meeting to discuss implementation of recent pharmacy benefit manager (PBM) legislation on September 6, 2023. 

Recording of Sept.6 Public Meeting

Slides from Sept.6 Public Meeting