Under Vermont laws and regulations, PBMs are required to complete a VHCURES and PBM registration on an annual basis. The instructions below will guide registrants to the consolidated on-line registration form designed to support VHCURES and PBM registration on a single form.
Before doing business in Vermont and on an annual basis prior to December 31 thereafter, any person or entity that performs pharmacy benefit management (a pharmacy benefit manager or “PBM”) is required to register with the State of Vermont. See 18 V.S.A. § 9421. This would include persons or entities in a contractual or employment relationship with a PBM performing pharmacy benefit management for a health plan. See 18 V.S.A § 9471.
As specified in Regulation H-2008-01 for VHCURES, health insurers providing services to Vermont residents including TPAs and PBMs are also required to register with the State’s designated claims data collection contractor Onpoint Health Data. After registering, registrants will be notified about whether they will be required to submit claims data to the State of Vermont based on a minimum enrollment threshold for each specified line of business including major comprehensive medical benefit plans, Medicare Supplement, Medicare Parts C and D. Bulletin No. HCA-125 contains a synopsis of the regulation pertaining to the registration requirement.
Under a separate program established by the state legislature and administered by the Agency of Human Services, health insurers including TPAs and PBMs providing services to Vermont residents are required to contribute to the Vermont Health Care Information Technology Reinvestment Fund with the exception of Medicare Parts C and D that are not subject to the surcharge.