On September 2, 2025, a U.S. District Court in Illinois dismissed an ERISA preemption lawsuit by Central States, Southeast, and Southwest Areas Health and Welfare Fund against the Arkansas Insurance Commissioner and Department. Specifically, the plaintiff (a self-funded, multiple employer welfare plan) challenged an Arkansas state rule that permits the Arkansas Insurance Commissioner (the commissioner) to review the adequacy of pharmacy reimbursement payments made by health plan PBMs, arguing t