The New Hampshire Pharmacy Benefits Manager license
Pharmacy Benefits Manager
A registration rather than a license, and the statute says so in its own heading. No examination, no course, and the whole application format is left to rules the commissioner writes.
Course
None
This license has no pre-licensing course route.
Ways in
1
There is no state exam for this license.
Exam
n/a
Not required on any of the routes below.
Every way to qualify
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Route 1 Register with the commissioner
No state exam for this license
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An application in the format the commissioner prescribes by rule, including the registrant’s corporate charter, articles of incorporation or other formation documents, and designated contact information so the Department can reach the manager about consumer complaints
RSA 402-N:2, I forbids establishing or operating as a pharmacy benefits manager for health benefit plans without registering with the insurance commissioner, and the section is headed "Registration to do Business" rather than licensure. Almost everything about the application is delegated: RSA 402-N:2, II tells the commissioner to make rules prescribing the format, requiring the corporate charter or formation documents, establishing application and renewal fees capped at $500 a year, and setting out how consumer complaints are handled and who at the manager the Department can reach about them. There is no examination, no course, no experience bar and no financial test in the statute. The penalty side is specific where the qualification side is not: $2,500 for each separate violation, and revocation or suspension of the registration. Thirty states here now carry a pharmacy benefits manager and they do not agree on where it belongs. Alaska licenses one at the insurance division for $20,000 and writes a duty of care into the licensing chapter; New Hampshire registers one for no more than $500 a year; and Rhode Island moves its to the Office of the Health Insurance Commissioner, a different regulator, from 2027-01-01.
Read at the Department on 2026-08-19
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No national seller sells a course for this registration. Nothing could: it is a corporate registration with no examination, no course and no individual qualification behind it.