Pharmacy Benefit Managers (PBM) go to great lengths so as not to be considered insurance, so some states have required a Third-Party Administrator (TPA) license, as the states adjudicate claims. Some PBM’s have free standing pharmacies (e.g. Maxor), and/or mail order pharmacies. Minnesota has taken a step to regulate beyond the traditional TPA and or Utilization Review Organization license by passing the Minnesota Pharmacy Benefit Manager Licensure and Regulation Act, Minn. Stat. 62W.02. Effective August 1, the statute regulates PBM’s relationships with carriers, requires the PBM’s to submit proof of network adequacy, and obligates PBM’s to certain pricing transparency rules not generally required by other states.