A New York pharmacy benefit manager (PBM) license is the license the Department of Financial Services (DFS) issues to a PBM before it may "begin or continue performing PBM services in New York" (DFS). This page is for PBMs entering New York or maintaining a New York license. Integral Healthcare Solutions (IHS) sequences your PBM license filing and maps the state's duties to your policies, including your URAC accreditation policies; your counsel owns statutory interpretation, and your PBM files.

Last reviewed: October 2026.

What is the New York PBM license?

The New York PBM license is a three-year license from DFS, applied for and paid for online. DFS states: "A PBM must apply for and obtain a license from the Department to begin or continue performing PBM services in New York" and "Obtaining a license to operate as a PBM in New York includes an application, submission of documentation, and the payment of a licensing fee. Apply for a PBM license and pay the fee through DFS Connect, a secure web-based system" (DFS, Pharmacy Benefit Managers).

The governing text, as DFS names it: "Insurance Law Article 29 (NYSenate.gov) and Section 280-a of the Public Health Law (NYSenate.gov) authorize the Department of Financial Services to regulate Pharmacy Benefit Managers operating in New York," together with the regulations promulgated under them. This page quotes the DFS license page and FAQ, read October 2026. It does not quote the statutes or the regulations, and it covers New York only; other states are scoped separately.

The license has a fixed term and ongoing duties. "Every license is valid for 3 years (36 months) from the date it is issued." A renewal filed "at least 60 days before it expires" keeps the existing license "in full force and effect until the issuance" of a decision on the renewal. And "An Annual Report must be completed and submitted to the Department by no later than July 1 each year" (DFS).

Who needs it and what triggers it

A PBM needs the license to perform PBM services in New York, and these events trigger the work:

• Entering New York. A PBM must obtain the license "to begin ... performing PBM services in New York" (DFS).
• Continuing in New York. The same sentence covers PBMs that "continue performing PBM services," and the license runs for 36 months, so each renewal is a filing.
• Workers' compensation business. DFS answers its own question, "Is an entity that provides PBM services exclusively in the workers' compensation industry required to obtain a license?", with "Yes," because "the broad definition of health plan in the law which includes any policy or plan that provides prescription drug coverage includes workers' compensation plans" (DFS FAQ).
• Changes to a licensed PBM, which your counsel reviews against the statute and regulations.
• The annual report cycle, due by July 1 each year.

DFS's FAQ, under its heading "FAQs About the Annual Report," answers "How do I determine whether 50% or more of the beneficiaries of a health plan work or reside in New York?" in these words (DFS FAQ, read October 2, 2026):

A beneficiary of a health plan is considered a New York beneficiary (i.e., someone who works or resides in New York) for purposes of New York Insurance Law Article 29, New York Public Health Law section 280-a, and the applicable regulations promulgated thereunder, when any of the following are true:

• The health plan is issued by an insurance company that is an authorized insurer under the insurance law, a company organized pursuant to article forty-three of the insurance law, a municipal cooperative health benefit plan established pursuant to article forty-seven of the insurance law, an entity certified pursuant to article forty-four of the public health law, an institution of higher education certified pursuant to section one thousand one hundred twenty-four of the insurance law, the state insurance fund, or the New York state health insurance plan established under article eleven of the civil service law,
• The beneficiary primary participant of the health plan has or had access to that health plan as a result of working in New York, or
• The beneficiary resides in New York.

For purposes of calculating the total number of beneficiaries under a health plan, each primary participant of the health plan and all beneficiaries under each primary participant should be counted as beneficiaries for purposes of calculating the total number of New York and non-New York beneficiaries under the health plan.

Once you have determined which beneficiaries are considered New York beneficiaries, you can then calculate what percentage of the total beneficiaries work or reside in New York.

The FAQ answer does not say what the percentage means for a license; the quoted text defines who counts as a New York beneficiary and how the percentage is calculated. How the result bears on your license or filings is a question for your counsel.

How IHS helps

IHS organizes the filing and the procedures behind it. The process:

1. Gap assessment. IHS assesses your current documents against the license application and the ongoing duties DFS lists, such as the annual report and renewal timing.
2. Questionnaires. IHS sends questionnaires on ownership, contracts and reporting.
3. Document and evidence mapping. IHS builds a filing sequence and a crosswalk from each application item to the exhibit that answers it.
4. Drafting. IHS drafts the reporting procedures and a policy crosswalk between your New York license duties and your URAC accreditation policies, so one policy set serves both. Your legal and pharmacy leaders review and approve them.
5. Filing review. IHS reviews the assembled filing against the crosswalk.
6. Filing support. IHS drafts cover text for your PBM to file in DFS Connect.

What you supply: ownership records, contracts, financials, current policies, and your legal and pharmacy leadership.

The limit: statutory interpretation and business decisions belong to your counsel and leadership, and your PBM files. IHS does not file in DFS Connect or correspond with DFS.

What to have ready

Each item ties to the DFS PBM license page or FAQ (read October 2026).

• A DFS Connect account for the person who will file, since DFS says to "Apply for a PBM license and pay the fee through DFS Connect" (DFS).
• The supporting documentation for the application; DFS describes the license as "an application, submission of documentation, and the payment of a licensing fee" (DFS).
• Payment for "the $24,000 non-refundable license application fee," payable "electronically via ACH or by credit card directly in DFS Connect" (DFS FAQ).
• A list of your lines of business, including any workers' compensation PBM services, which DFS says require a license (DFS FAQ).
• For each health plan you serve, a count of the primary participants and all beneficiaries under each, split between New York beneficiaries (the plan is issued by one of the listed New York entity types, the primary participant has or had access to the plan through working in New York, or the beneficiary resides in New York) and others, because the DFS FAQ calculates the percentage from "the total number of New York and non-New York beneficiaries under the health plan" (DFS FAQ).
• A license calendar: the 36-month term and a renewal filing date at least 60 days before expiration (DFS).
• An annual report calendar with the July 1 due date (DFS).
• Your counsel's copies of Insurance Law Article 29, Public Health Law section 280-a and the regulations under them, which DFS names as its authority (DFS).

How it compares

The New York license and URAC Pharmacy Benefit Management accreditation are separate. The license is a state requirement to perform PBM services in New York (DFS); URAC accreditation is a private review against URAC's standards. IHS also offers URAC PBM accreditation consulting, and the policy crosswalk on this page connects the two sets of duties. Licensure in other states is filed state by state and is not covered here.

What it costs

A New York license has two cost parts: the DFS fee and your own counsel and staff time. DFS's FAQ states that "a PBM can pay the $24,000 non-refundable license application fee electronically via ACH or by credit card directly in DFS Connect" (DFS FAQ, read October 2026). Verify current fees with DFS. IHS scopes each engagement after a free introductory call.

What this is not

• It is not legal advice. Your counsel interprets Insurance Law Article 29, Public Health Law section 280-a and the regulations.
• It is not a guarantee of DFS's decision. DFS decides whether to issue or renew the license.
• IHS does not file with or correspond with DFS for you. IHS drafts; your PBM files.

Frequently asked questions

Does a pharmacy benefit manager need a license to operate in New York?

Yes. DFS states: "A PBM must apply for and obtain a license from the Department to begin or continue performing PBM services in New York" (DFS).

How much is the New York PBM license fee?

DFS's FAQ states "the $24,000 non-refundable license application fee," paid "electronically via ACH or by credit card directly in DFS Connect" (DFS FAQ). Verify current fees with DFS.

How do we apply for a New York PBM license?

Through DFS Connect. DFS says the license "includes an application, submission of documentation, and the payment of a licensing fee" and to "Apply for a PBM license and pay the fee through DFS Connect, a secure web-based system" (DFS). Your PBM files; IHS drafts the cover text and builds the exhibit crosswalk.

How long is a New York PBM license valid, and when must we renew?

"Every license is valid for 3 years (36 months) from the date it is issued" (DFS). If the renewal application is filed at least 60 days before expiration, the existing license "continues in full force and effect until the issuance" of a decision on the renewal.

When is the New York PBM Annual Report due?

"An Annual Report must be completed and submitted to the Department by no later than July 1 each year" (DFS). IHS drafts the reporting procedure that assigns owners and dates for it.

Do workers' compensation-only PBMs need a New York license?

Yes, per DFS's FAQ: "the broad definition of health plan in the law which includes any policy or plan that provides prescription drug coverage includes workers' compensation plans" (DFS FAQ).

How do we count New York beneficiaries for the 50% test?

DFS's FAQ, under "FAQs About the Annual Report," says a beneficiary is a New York beneficiary "when any of the following are true": the health plan is issued by one of the New York entity types the FAQ lists, "The beneficiary primary participant of the health plan has or had access to that health plan as a result of working in New York," or "The beneficiary resides in New York." For the total, "each primary participant of the health plan and all beneficiaries under each primary participant should be counted." DFS then says you "can then calculate what percentage of the total beneficiaries work or reside in New York." The FAQ answer does not say what the percentage means for a license; ask your counsel (DFS FAQ).

How do New York licensing duties line up with URAC PBM accreditation?

They are separate obligations: the license is a state requirement, and URAC accreditation is a private review. IHS drafts a policy crosswalk between your New York duties and your URAC accreditation policies so one policy set can serve both.

Does this cover PBM licensing in other states?

No. This page covers New York only. Other states are scoped separately, one state at a time.