Pharmacy MAC Rights

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Arizona PBM MAC rights

Statute A.R.S. § 20-3331

Read this one carefully. The research turned up something about this state that could mislead you if skimmed — usually a repeal, a renumbering, or a stale official page. The detail is in the fields below.

Can you demand the MAC list?
No — only the sources, not the list

Whether the statute gives a pharmacy a right to see the list of drugs priced off maximum allowable cost.

What format must it be in?
none

Some states require it to be electronic and searchable. Most say nothing, which in practice means a PDF.

How often must prices update?
7 b.d.

A demonstrably staler list is itself a violation in most states.

How long do you have to appeal?
⚠️ No window in statute — only a duty to "establish a process." A PSAO may appeal on behalf of its network

Read the trigger carefully. A clock running from adjudication is much shorter in practice than one running from payment.

How fast must they answer?
none
What must a denial tell you?
Neither NDC nor wholesaler — Arizona imposes no denial duty at all

The strongest provision in this area. A named drug code, and better a named wholesaler, is a claim you can check against your own catalogue.

Does winning fix it for everyone?
silent

In a few states a successful appeal corrects the price for every similarly situated pharmacy, sometimes retroactively.

What are the penalties?
≤$1,000/act ($10,000 aggregate); $5,000/act and $50,000 per 6 months if intentional

The weakest column in our data. Several are marked unverified rather than guessed at.

Who enforces it?
Dept. of Insurance & Financial Institutions
Enacted / last amended
2019, unchanged through the 2025 text

Before you rely on a deadline, know which plan is behind the claim

State MAC rights are strongest on commercial claims — individual plans, fully insured employer plans, and in many states the state employee plan. For self-funded employer plans they stand, because the Supreme Court's 2020 Rutledge decision specifically upheld MAC update and appeal mandates.

Medicare Part D is the real problem. Federal law expressly supersedes state regulation of Part D plans, two federal circuits apply that rule at very different levels of generality, and in Arkansas a federal court entered final judgment that the state MAC law is preempted as to Part D. Part D is roughly a quarter of a typical independent's volume, so this is not a footnote.

Medicaid depends entirely on your own state's statute — some exempt it by name, some cover it by name, most are silent. TRICARE and federal-employee claims should be treated as outside these rights.

What to do with this

  1. Check your own contract first. In most states it has to name the pricing sources the PBM uses. That is a document you already have.
  2. Ask for the list. There is a free template here. No state publishes one, so we wrote it.
  3. Send it to the right place. Sixty-odd licensed PBMs collapse to about eight actual appeal endpoints. Here is where each one goes.
  4. Tell us what happened. Nobody publishes whether these duties are actually honoured. Two minutes, and it becomes public data.

Sources

Spotted something wrong on this page? Tell us and we will check it — corrections are the most useful thing anyone sends us.

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