This January 12th, 2018 letter outlines PCMA’s concerns with NJ bill A. 4676. A. 4676 would require PBMs to register with the New Jersey Department of Banking and Insurance (DOBI) as an organized delivery system (ODS). DOBI already has direct regulatory authority over PBMs operating within the State. PCMA asked for a veto request because A.4676 creates the wrong regulatory scheme for PBMs, which do not neatly fit into the construction of the ODS statute or regulations. Defining a PBM as an ODS would place significant regulatory burden on PBMs, potentially driving up costs for the employers and plan sponsors.