Health Care & Wellness
Pharmacy Benefit Manager (PBM) Legislation Tackled Ownership Restrictions, Transparency, and More in 2025
January 27, 2026 | Lisa Kimbrough
January 27, 2026 | Amber Thyson
Key Takeaways:
At the end of each year, our policy analysts share insights on the issues that have been at the forefront of state legislatures throughout the session during their review of thousands of bills across all 50 states. Here are the big developments and high-level trends we saw last year in the vaccine policy space, plus what you can expect in 2026.
The COVID-19 pandemic significantly altered public health governance in the U.S., requiring refined collaboration among federal, state, and healthcare entities. Initially, the federal government advocated for universal vaccination, recommending COVID-19 vaccines for everyone six months and older. However, in September 2025, federal guidance shifted, revoking emergency use authorizations for the vaccines and limiting eligibility to adults 65 and older and individuals with specific health conditions. For others, vaccination now requires consultation with a healthcare provider. This change has impacted pharmacy practices, as state laws in Massachusetts, Nevada, and New Mexico restrict vaccine administration to only those who meet federal eligibility criteria, even with a prescription. Approximately 16 other states also have age-based and prescription requirements for vaccination. This shift has sparked concerns among policymakers and health advocates, who worry it could decrease vaccine uptake, increase health inequities, and damage public trust in the healthcare system.
In reaction to federal changes, at least 18 states have taken action to protect vaccine access, often led by Democratic governors. These states implemented various measures, such as issuing executive orders to allow pharmacies to administer vaccines without prescriptions and ensuring insurers continue covering COVID-19 vaccinations. Some states also chose to rely on independent medical organizations to set eligibility criteria instead of federal guidance.
Conversely, Florida is moving to eliminate nearly all vaccine mandates, including those for schoolchildren, college students, and nursing home residents. The Department of Health has recently announced that some school vaccination rules, such as those for chickenpox and hepatitis B, will be dropped after a 90-day period, though mandates for serious illnesses like measles, polio, and diphtheria remain in place until legislative action. The proposal has sparked debate among public health experts and will face further review in the 2026 legislative session.
Regional health alliances have also been proactive. The West Coast Health Alliance (WCHA) released winter vaccination recommendations for California, Hawaii, Oregon, and Washington, based on guidance from leading medical organizations. Similarly, the Northeast Public Health Collaborative, which includes several states and New York City, officially launched in September to address federal vaccine policy changes, reaffirming their commitment to science-based, equitable public health practices.
Another group to watch will be the newly formed Governor’s Public Health Alliance. Launched on October 15, 2025, by a bipartisan group of 15 governors, the coalition was designed to improve public health coordination across state lines, especially in response to growing federal inaction and emerging health threats. While the Alliance has yet to develop formal policies, Massachusetts Governor Maura Healey (D) remarked: “While Donald Trump and RFK Jr. turn their backs on public health, Governors are stepping up to make sure our residents have the health care they need and deserve…Massachusetts is glad to join this coalition with states from across the country to build on the work we’ve been doing in the northeast to safeguard public health, including access to vaccines.”
In response to the federal shift, AHIP, the national trade association of health insurers, confirmed that its members will continue to cover all ACIP-recommended vaccines, including updated COVID-19 and flu vaccines, with no cost-sharing for patients through the end of 2026. This decision aims to alleviate concerns about reduced coverage following the changes in federal policy.
As federal vaccine guidance becomes more variable, we’re likely to see many states strengthen independent state-level mandates and insurance requirements—requiring insurers to cover vaccines endorsed by state health departments (even if not backed by the CDC) and expanding pharmacist authority. States will also continue to form regional collaboratives or alliances to coordinate vaccine guidance and procurement. Conversely, in some states there will be pushback: rollbacks of school vaccine mandates, lifting vaccine requirements, and emphasizing parental choice. Throughout, preserving no-cost access (including through Medicaid and private insurers) will be a big focus, since insurers and state laws are committing to continue covering ACIP-recommended vaccines (or equivalents) through 2026.
StateVitals is the leading resource on how state governments are shaping healthcare policy and transforming care and delivery, brought to you by MultiState’s Health Care Policy Practice. MultiState’s policy and advocacy professionals are uniquely positioned to give you and your organization the big-picture view on state health policy reform, plus the latest trends on how policymakers are thinking about healthcare and similar emerging issues. Learn more about StateVitals, or schedule a demo here.
January 27, 2026 | Lisa Kimbrough
January 23, 2026 | Mary Kate Barnauskas
January 16, 2026 | Bill Kramer