Lexology January 23, 2026
The 2026 Consolidated Appropriations Act, HR 7148, was passed by the U.S. House of Representatives on January 22, 2026. It includes several significant provisions impacting pharmacy benefit managers (PBMs), with one of the most consequential changes being Congress’ directive to the Centers for Medicare and Medicaid Services (CMS) to define and enforce what constitutes “reasonable and relevant” contract terms between Medicare Part D plans (and their PBMs) and pharmacies. These changes have particular importance for the operation and enforcement of “any willing pharmacy” (AWP) requirements.
Medicare Part D includes a statutory AWP requirement designed to promote beneficiary access to pharmacy services. In general terms, AWP requires that a Part D plan permit any pharmacy to participate in the network, so...
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