Recently, the Tennessee Senate passed a bill (SB 1852) that required any person serving in the state as a pharmacy benefits manager (PBM) to get licensure from the department of commerce and insurance before he or she starts any operations (Tennessee General Assembly, n.d.). Besides, the bill made it a criminal offense to administer a device or medication portion of pharmacy benefits coverage offered by a covered entity or otherwise play the role of a PBM in Tennessee in the absence of the licensure. The bill set out many eligibility requirements, which range from showing that one is financially responsible as determined by the department of commerce and insurance and pay a fee
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