6th Circuit Affirms That ERISA Partly Preempts Tennessee PBM Laws

( April 8, 2026, 12:35 PM EDT) -- CINCINNATI — Affirming that the Employee Retirement Income Security Act expressly preempts parts of Tennessee pharmacy benefit manager (PBM) laws, the Sixth Circuit U.S. Court of Appeals on April 7 called Pharm. Care Mgmt. Ass’n v. Mulready “instructive” and concluded that the laws’ any-willing-provider (AWP) and incentive provisions that apply to self-funded health plans are impermissibly connected with ERISA....