Oklahoma Medicaid GLP-1 Coverage 2026: Pattern #24 — Triple-Carve-Out Regulatory-Exclusion State with University of Oklahoma College of Pharmacy-Administered PA

TL;DR — What Oklahoma SoonerCare Actually Covers

Pattern #24 in the 50-State Taxonomy: Triple-Carve-Out Regulatory-Exclusion State with University-Administered PA Infrastructure

The 24-state taxonomy in this series maps each state to its structural posture toward GLP-1 anti-obesity coverage. Oklahoma is Pattern #24 — a categorical regulatory-exclusion state (like Texas, Illinois, Alabama, and Kentucky) but with the highest number of DUR-Board-approved FDA-label-restricted carve-outs of any state in the cluster to date: four.

Oklahoma is also the only state in this 24-state series whose pharmacy benefit prior-authorization infrastructure is administered by a state university’s college of pharmacy rather than a national PBM. Every other state in the series — Texas (Acentra), Alabama (Acentra Health), Kentucky (MedImpact), Pennsylvania (Change Healthcare/Optum), Missouri (Conduent/Gainwell), Tennessee (Magellan Rx/Prime Therapeutics) — uses a national or regional commercial PBM. Oklahoma uses Pharmacy Management Consultants (PMC) at the University of Oklahoma College of Pharmacy, which drafts every PA-criteria recommendation that the OHCA Drug Utilization Review (DUR) Board votes on, and evaluates more than 8,000 PA requests per month.

The structural comparison with its nearest analogs:

• Alabama (Pattern #23): categorical exclusion at Ala. Admin. Code r. 560-X-16-.01(2)(b) + Zepbound OSA (PDL footnote) + Wegovy MACE (PA Form 369) = 2 carve-outs, national PBM (Acentra Health), non-expansion state.
• Kentucky (Pattern #21): categorical exclusion at 907 KAR 23:010 Section 5(2)(a) + Wegovy MACE/MASH + Zepbound OSA = 3 carve-outs, MedImpact PBM, expansion state (2014), but July 2026 restriction threat from SB 65 veto override.
• Oklahoma (Pattern #24): categorical exclusion at OAC 317:30-5-72.1(1)(D) + Wegovy CV + Wegovy MASH + Zepbound OSA + Imcivree monogenic-obesity = 4 carve-outs, OU College of Pharmacy PA administration (unique in cluster), expansion state (SQ 802, July 2021) with active 2026 defunding-ballot legislation (HJR 1067/HB 4440).

Oklahoma is NOT among the 13 KFF-classified states covering GLP-1s for chronic weight management as of January 2026. Oklahoma has instead taken a structurally different approach: adding FDA-label-restricted carve-outs sequentially through DUR Board votes (October 2024 for Wegovy CV, March 2026 for Wegovy MASH + Zepbound OSA + Imcivree pediatric age expansion) without adding the chronic-weight-management indication.

The Regulatory Anchor: OAC 317:30-5-72.1(1)(D) and the Federal Optional-Exclusion Authority

The categorical exclusion that bars GLP-1 anti-obesity coverage in Oklahoma SoonerCare is codified at OAC 317:30-5-72.1(1)(D) — Title 317 of the Oklahoma Administrative Code (Oklahoma Health Care Authority), Chapter 30 (Medical Providers-Fee For Service), Subchapter 5 (Individual Providers and Specialties), Part 5 (Pharmacies), Rule 317:30-5-72.1 (Drug benefit). The operative subsection:

“(D) Agents used primarily for the treatment of anorexia or weight gain. Drugs used primarily for the treatment of obesity, such as appetite suppressants are not covered. Drugs used primarily to increase weight are not covered unless otherwise specified.”

This is the canonical primary citation. The rule was last substantively revised effective September 1, 2021. The phrase “unless otherwise specified” is the regulatory mechanism that enables the four DUR-Board-approved carve-outs: Wegovy is “otherwise specified” for CV risk reduction and noncirrhotic MASH; Zepbound is “otherwise specified” for OSA; Imcivree is “otherwise specified” for monogenic obesity.

The state rule is subordinate to — but fully consistent with — the federal permissive exclusion authority at 42 U.S.C. § 1396r-8(d)(2)(A):

“(2) The following drugs or classes of drugs, or their medical uses, may be excluded from coverage or otherwise restricted: (A) Agents when used for anorexia, weight loss, or weight gain.”

The federal statute uses “may be excluded” — it is permissive, not mandatory. Oklahoma has elected to invoke this exclusion for the general chronic-weight-management indication while preserving four FDA-label-specific carve-outs. Amending OAC 317:30-5-72.1 to add general chronic-weight-management coverage would require a formal rulemaking docket through the OHCA Office of Legal Services and legislative review through the Joint Committee on Administrative Rules — not a quarterly DUR Board vote.

The 13 KFF-classified covering states as of January 2026 have made the opposite policy choice, electing NOT to invoke the federal exclusion authority for the chronic-weight-management FDA indication. Oklahoma has not made that choice as of 2026-05-10.

Carve-Out #1: Wegovy (Semaglutide Injection and Tablets) for Cardiovascular Risk Reduction Only — DUR Board Recommendation 5, October 9, 2024 (Updated March 11, 2026)

The first DUR-Board-approved carve-out came on October 9, 2024, following the March 2024 FDA expansion of Wegovy’s label to include reduction of major adverse cardiovascular events (MACE) in adults with established cardiovascular disease and obesity or overweight. The DUR Board action, designated Recommendation 5, was carried by unanimous approval. The DUR Board Packet stated verbatim:

“Recommendation 5: Vote to Prior Authorize Wegovy® (Semaglutide)
MOTION CARRIED by unanimous approval.
The College of Pharmacy recommends the prior authorization of Wegovy® (semaglutide) with the following criteria (shown in red):

Wegovy® (Semaglutide) Approval Criteria [Cardiovascular (CV) Risk Reduction Indication Only]:
1. An FDA approved indication to reduce the risk of major adverse cardiovascular (CV) events in members with established CV disease (CVD) and either obesity or overweight; and
  a. Wegovy® will not be approved for obese or overweight members in the absence of established CVD; and
2. Member must be 45 years of age or older; and
3. Member must have established CVD with a history of 1 of the following (documentation must be submitted with the request):
  a. Previous myocardial infarction; or
  b. Previous stroke; or
  c. Symptomatic peripheral arterial disease confirmed by 1 of the following:
    i. Intermittent claudication with ankle-brachial index <0.85 at rest; or
    ii. Peripheral arterial revascularization procedure; or
    iii. Amputation due to atherosclerotic disease; and
4. Member has a body mass index (BMI) ≥27 kg/m²; and
5. Member does not have type 1 diabetes mellitus (T1DM) or type 2 diabetes mellitus (T2DM); and
6. Member has a hemoglobin A1C (HbA1c) <6.5%; and
7. Member will not be using Wegovy® in combination with other semaglutide-containing products or any other glucagon-like peptide-1 (GLP-1) receptor agonist; and
8. Member is currently receiving guideline-directed management and therapy (GDMT) for CVD (e.g., antihypertensives, lipid-lowering agents, antiplatelets), as documented in the member’s pharmacy claims history, unless contraindicated; and
9. Wegovy® must be used in conjunction with diet and exercise (clinical documentation of member’s diet and exercise program must be included with the request); and
10. Initial approvals will be for the titration period to allow initial and escalation dosing. A separate prior authorization request must be submitted for each dose; and
  a. Approvals will be for 8 weeks at a time to allow for proper dose escalation [amended from 4 weeks at March 11, 2026 DUR Board]; and
  b. An additional 8 weeks for each dose may be approved for those who experience intolerable adverse effects during dose escalation with proper documentation; and
  c. Members who cannot tolerate dose escalation after an additional 8-week approval will not be approved for continuation; and
11. Subsequent approvals for the maintenance dose (1.7mg or 2.4mg) will be approved for 1 year if the prescriber documents the following:
  a. Member is tolerating maintenance dosing; and
  b. Member has not developed T1DM or T2DM; and
  c. Member is continuing all of the following in conjunction with Wegovy®:
    i. Reduced calorie diet; and
    ii. Increased physical activity; and
    iii. GDMT for CVD where applicable; and
12. A quantity limit of 4 pens per 28 days will apply; and
13. Wegovy® should be discontinued in members who cannot tolerate at least the 1.7mg once weekly maintenance dosing.”

The March 11, 2026 DUR Board (Recommendation 15) updated the title to “Wegovy® (Semaglutide Injection and Tablets)” to incorporate the December 2025 FDA approval of oral Wegovy tablets (1.5 mg, 4 mg, 9 mg, 25 mg) for the CV indication, and amended the titration window from 4 weeks to 8 weeks via a motion by Dr. Kupiec, seconded by Dr. Weakley.

Who this carve-out reaches: Only adults age 45 or older with confirmed prior MI, prior stroke, or symptomatic PAD, BMI ≥ 27, and NO T1DM or T2DM (A1C < 6.5% as confirmation). Members with T2DM who also have cardiovascular disease are not eligible via this pathway — they are routed to the Anti-Diabetic Medications Tier-2 criteria for Ozempic/Trulicity (T2DM indication only). This is the narrowest applicable population in the carve-out structure.

Carve-Out #2: Wegovy (Semaglutide Injection) for Noncirrhotic MASH Only — DUR Board Recommendation 15, March 11, 2026

The second carve-out — for Metabolic Dysfunction-Associated Steatohepatitis (MASH) — was approved on March 11, 2026 as part of DUR Board Recommendation 15, following the August 2025 FDA accelerated approval of Wegovy for noncirrhotic MASH with stage F2 or F3 liver fibrosis (the ESSENCE trial primary endpoint: 63% of Wegovy participants achieved MASH resolution vs. 34% on placebo). The verbatim approved criteria:

“Wegovy® (Semaglutide Injection) Approval Criteria [Metabolic Dysfunction-Associated Steatohepatitis (MASH) Diagnosis Only]:
1. An FDA approved indication of noncirrhotic MASH; and
  a. Wegovy® will not be approved for obese members in the absence of MASH; and
2. Member must be 18 years of age or older; and
3. Member must have moderate-to-advanced liver fibrosis (e.g., stage F2 or F3) confirmed by at least 1 of the following (results of the selected test must be submitted with the request):
  a. FibroScan with vibration controlled transient elastography (VCTE) ≥8kPa and controlled attenuation parameter (CAP) ≥280dB/min; or
  b. Enhanced Liver Fibrosis (ELF) biochemical test score ≥9; or
  c. Liver biopsy showing stage F2 or F3 fibrosis with MASH; and
4. Member must not have chronic liver disease other than metabolic dysfunction-associated steatotic liver disease (MASLD); and
5. Member does not have type 1 diabetes mellitus (T1DM) or type 2 diabetes mellitus (T2DM); and
6. Wegovy® must be used in conjunction with diet and exercise [clinical documentation (e.g., office notes) of member’s diet and exercise program this discussion with the member must be included with the request]; and
7. Prescriber must attest that metabolic comorbidities are being appropriately managed, including treatment for all of the following, if applicable:
  a. T2DM; and
  b. Dyslipidemia; and
  c. Hypertension; and
8. Member will not be using Wegovy® in combination with other semaglutide-containing products or any other glucagon-like peptide-1 (GLP-1) receptor agonist; and
9. Must be prescribed by, or in consultation with, a gastroenterologist or hepatologist (or an advanced care practitioner with a supervising physician who is a gastroenterologist or hepatologist); and
10. Initial approvals will be for the titration period to allow initial and escalation dosing. A separate prior authorization request must be submitted for each dose; and
  a. Approvals will be for 8 weeks at a time to allow for proper dose escalation; and
  b. An additional 8 weeks for each dose may be approved for those who experience intolerable adverse effects during dose escalation with proper documentation; and
  c. Members who cannot tolerate dose escalation after an additional 8 week approval will not be approved for continuation; and
11. Subsequent approvals for the maintenance dose (1.7mg or 2.4mg) will be approved for 1 year if the prescriber documents the following:
  a. Member is tolerating maintenance dosing; and
  b. Member has not developed T1DM or T2DM; and
  c. Member is continuing a reduced calorie diet and increased physical activity in conjunction with Wegovy®; and
12. A quantity limit of 4 pens per 28 days will apply; and
13. Wegovy® should be discontinued in members who cannot tolerate at least the 1.7mg once weekly maintenance dosing.”

Criterion 9 — the gastroenterologist or hepatologist consultation requirement — is a structural barrier for rural Oklahoma members. The OHCA DUR Board packets do not document a specific Oklahoma gastroenterologist-shortage metric, but the consultation requirement creates a referral-access dependency that members in rural counties may face. This pathway is also restricted to injection Wegovy only (not the oral tablet form, which is covered only under the CV carve-out).

Carve-Out #3: Zepbound (Tirzepatide) for Obstructive Sleep Apnea Only — DUR Board Recommendation 15, March 11, 2026

Oklahoma became one of the first states to adopt DUR-Board-approved PA criteria for Zepbound for obstructive sleep apnea (OSA) following the December 20, 2024 FDA approval of Zepbound as the first FDA-approved medication for OSA. The process began with a 30-day notice in the January 14, 2026 DUR Packet (Recommendation 3: “NO ACTION REQUIRED; WILL BE AN ACTION ITEM IN FEBRUARY 2026”), proceeded to an initial vote at the February 11, 2026 meeting, and was finalized with the 4-to-8-week titration amendment at the March 11, 2026 DUR Board meeting. The verbatim final criteria:

“Recommendation 15: Vote to Prior Authorize Zepbound® (Tirzepatide) and Update the Approval Criteria for the Adiposity-Based Chronic Disease (ABCD) Medications
MOTION CARRIED by unanimous approval.

The College of Pharmacy recommends the prior authorization of Zepbound® (tirzepatide) with the following criteria, including updates to the diet and exercise criteria in #9 for clarity and updates to #11 to update the 4-week approvals to 8 weeks to relieve logistical challenges of delays in the titration process as recommended by and approved unanimously by the DUR Board (shown in red):

Zepbound® (Tirzepatide) Approval Criteria [Obstructive Sleep Apnea (OSA) Indication Only]:
1. An FDA approved indication of moderate to severe OSA in members with obesity; and
  a. Zepbound® will not be approved for obese members in the absence of OSA; and
2. Member must be 18 years of age or older; and
3. Member must have moderate-to-severe OSA defined as an apnea-hypopnea index (AHI) ≥15 determined by a polysomnography (PSG) or home sleep apnea testing (HSAT) with a technically adequate device (AHI value must be provided); and
4. Member has a body mass index (BMI) ≥30 kg/m²; and
5. Member must not have central or mixed sleep apnea; and
6. Member does not have type 1 diabetes mellitus (T1DM) or type 2 diabetes mellitus (T2DM); and
7. Member has a hemoglobin A1C (HbA1c) <6.5%; and
8. Member will not be using Zepbound® in combination with other tirzepatide-containing products or any other glucagon-like peptide-1 (GLP-1) receptor agonist; and
9. Zepbound® must be used in conjunction with behavioral changes and/or a reduced calorie diet [clinical documentation (e.g., office notes) of member’s diet and exercise program this discussion with the member must be included with the request]; and
10. For Zepbound® vials or KwikPen®, a patient-specific, clinically significant reason why the member cannot use the pen formulation must be provided (Zepbound® pens are preferred over the vials and KwikPen®); and
11. Initial approvals will be for the titration period to allow initial and escalation dosing. A separate prior authorization request must be submitted for each dose; and
  a. Approvals will be for 8 weeks at a time to allow for proper dose escalation; and
  b. An additional 8 weeks for each dose may be approved for those who experience intolerable adverse effects during dose escalation with proper documentation; and
  c. Members who cannot tolerate dose escalation to at least 5mg after an additional 8-week approval will not be approved for continuation; and
12. Subsequent approvals for the maintenance dose (5mg to 15mg) will be approved for 1 year if the prescriber documents the following:
  a. Member is tolerating maintenance dosing and adherent to therapy; and
  b. Clinical improvement of OSA (e.g., patient-reported improvement in daytime sleepiness, partner-reported reduction of snoring episodes or pauses in breathing, reduction of AHI events); and
  c. Member has not developed T1DM or T2DM; and
  d. Member is continuing a reduced calorie diet and increased physical activity in conjunction with Zepbound®; and
13. A quantity limit of 4 pens or vials (2mL) per 28 days or 1 KwikPen® (2.4mL) per 28 days will apply; and
14. Zepbound® should be discontinued in members who cannot tolerate at least the 5mg once weekly maintenance dosing.”

As of 2026-05-10, no standalone PHARM-XXX form for Zepbound has been published on the OHCA Pharmacy Forms page. Providers seeking to submit a Zepbound OSA PA should call the OHCA Pharmacy Help Desk at 1-800-522-0114 Option 4 for current submission guidance.

The pen-preferred mechanism in criterion 10 — requiring a patient-specific reason to use vials or KwikPen over pens — is a cost-management mechanism similar to MO HealthNet’s preferred- formulation logic and is operationally enforced through OHCA point-of-sale claim adjudication.

Carve-Out #4: Imcivree (Setmelanotide) for Monogenic Obesity (POMC / PCSK1 / LEPR Deficiency or Bardet-Biedl Syndrome) — the ONLY Chronic-Weight-Management Indication Covered by Oklahoma Medicaid

Oklahoma is the only state in this 24-state series with Imcivree (setmelanotide) chronic-weight-management criteria documented at the DUR-Board PA-criteria level. This pathway covers chronic weight management for pediatric patients age 2 and older and adults with monogenic obesity — but it is explicitly NOT a general-obesity pathway. The DUR Board Recommendation 15 (March 11, 2026) updated the criteria to incorporate the December 2024 FDA pediatric age expansion from age 6+ to age 2+ for BBS and POMC/PCSK1/LEPR deficiency. The verbatim approved criteria:

“Finally, the College of Pharmacy recommends the following changes to the Imcivree® (setmelanotide) approval criteria based on the new FDA approved age expansion and clinical practice (changes shown in red):

Imcivree® (Setmelanotide) Approval Criteria:
1. An FDA approved indication of chronic weight management in adult and pediatric members 2 years of age and older with obesity due to 1 of the following:
  a. Proopiomelanocortin (POMC), proprotein convertase subtilisin/kexin type 1 (PCSK1), or leptin receptor (LEPR) deficiency; or
  b. Bardet-Biedl syndrome (BBS); and
2. For POMC-, PCSK1-, or LEPR-deficiency, diagnosis must be confirmed by molecular genetic testing to confirm homozygous or compound heterozygous variants in the POMC, PCSK1, or LEPR genes that are interpreted as pathogenic, likely pathogenic, or of uncertain significance (results of genetic testing must be submitted); and
3. For BBS, diagnosis must be confirmed by the following:
  a. Molecular genetic testing to confirm homozygous or compound heterozygous variants in a BBS gene that are interpreted as pathogenic or likely pathogenic (results of genetic testing must be submitted); and
  b. Clinical features of BBS supported by detailed clinical documentation of each feature (medical records/clinical documentation of each feature must be submitted), as follows:
    i. Four primary features (i.e., rod-cone dystrophy, polydactyly, obesity, learning disabilities, hypogonadotropic hypogonadism and/or genitourinary anomalies, renal anomalies); or
    ii. Three of the primary features previously listed in 3.b.i. plus 2 secondary features [i.e., speech disorder/delay, strabismus/cataracts/astigmatism, brachydactyly/syndactyly, developmental delay, poor coordination/imbalance, mild spasticity (especially lower limbs), diabetes mellitus, dental crowding/hypodontia/small roots/high arched palate, left ventricular hypertrophy/congenital heart disease, hepatic fibrosis]; and
4. Requests for Imcivree® for obesity due to suspected POMC-, PCSK1-, or LEPR-deficiency with POMC, PCSK1, or LEPR variants classified as benign or likely benign, or other types of obesity not related to POMC, PCSK1 or LEPR deficiency, or BBS including obesity associated with other genetic syndromes, or general obesity will not be approved; and
5. Member is currently on a dietician-guided diet and exercise program and has previously failed a dietician-guided diet and exercise program alone; and
6. Member’s baseline weight and body mass index (BMI) must be provided; and
7. Baseline BMI must be ≥30 kg/m² for adults or ≥95th percentile on BMI-for-age growth chart assessment for children; and
8. Member must not be actively suicidal or have uncontrolled depression and prescriber must verify member will be monitored for depression prior to starting Imcivree® therapy and throughout treatment; and
9. Prescriber must verify member has been counseled on potential sexual adverse reactions and when to seek emergency medical care; and
10. Prescriber must verify member does not have end stage renal disease [eGFR <15 mL/min/1.73m²] and must confirm the dose will be adjusted per package labeling for members with severe renal impairment (eGFR 15 to 29 mL/min/1.73m²); and
11. Prescriber must verify female member is not pregnant or breastfeeding; and
12. Prescriber must confirm member or caregiver has been trained on the proper storage and administration of Imcivree® prior to the first dose; and
13. For POMC-, PCSK1-, or LEPR-deficiency, initial approvals will be for the duration of 16 weeks. Reauthorization may be granted if the prescriber documents the member’s current weight or BMI and member has achieved weight loss of ≥5% of baseline body weight or ≥5% of BMI; or
14. For BBS, approvals will be for the duration of 1 year. Reauthorization may be granted if the prescriber documents the member’s current weight or BMI and member has achieved weight loss of ≥5% of baseline body weight or ≥5% of BMI; and
15. A quantity limit of 9mL per 30 days will apply.”

Criterion 4 is the canonical exclusion sentence that must be understood by any patient or provider approaching this pathway:

“Requests for Imcivree® for obesity due to suspected POMC-, PCSK1-, or LEPR-deficiency with POMC, PCSK1, or LEPR variants classified as benign or likely benign, or other types of obesity not related to POMC, PCSK1 or LEPR deficiency, or BBS including obesity associated with other genetic syndromes, or general obesity will not be approved.”

Population context: The number of Oklahoma SoonerCare members who carry the relevant genetic mutations is extremely small. BBS prevalence is approximately 1:140,000 to 1:160,000 — Oklahoma has a population of roughly 4.0 million, suggesting approximately 25–30 BBS-affected residents total. POMC/PCSK1/LEPR deficiency is rarer still. This pathway is real and explicitly documented, but it does NOT represent coverage for the general population seeking GLP-1 anti-obesity treatment.

The December 2024 FDA action that is incorporated in these updated criteria was an age expansion of the existing Imcivree indication (originally approved August 2020) from age 6+ to age 2+. It was not a new approval.

Unique PA Infrastructure: University of Oklahoma College of Pharmacy / Pharmacy Management Consultants (PMC)

Oklahoma SoonerCare’s prior-authorization infrastructure is structurally distinctive from every other state in this 24-state series. Rather than contracting with a national PBM (as Texas, Alabama, Kentucky, and most other states do), OHCA has since the 1990s contracted with Pharmacy Management Consultants (PMC), a unit of the University of Oklahoma College of Pharmacy at the OU Health Sciences Center campus, to administer the Product Based Prior Authorization (PBPA) program.

PMC’s operational role is three-fold:

1. PA-criteria drafting: PMC prepares every PA-criteria recommendation and product summary that the OHCA DUR Board votes on at its monthly meetings. The DUR Board — chaired (as of February 2026) by Bret Haymore, M.D. (Oklahoma State Medical Association) with vice-chair Edna Patatanian, Pharm.D., FASHP (Oklahoma Pharmacists Association) — meets the second Wednesday of each month. In practice, the OHCA nearly universally adopts DUR Board recommendations because the PMC clinical recommendations are operationally rigorous and cost-modeled.
2. PA adjudication: PMC evaluates more than 8,000 PA requests per month across all covered drug classes, not just anti-obesity agents. The mailing address on every OHCA PA criteria document is: University of Oklahoma College of Pharmacy, Pharmacy Management Consultants, Product Based Prior Authorization Unit, ORI-4403, P.O. Box 26901, Oklahoma City, OK 73126-0901.
3. Pharmacy Help Desk operation: PMC operates the OHCA Pharmacy Help Desk at 1-800-522-0114 Option 4 (phone) and 1-800-224-4014 (fax). The SoonerSelect-specific line is 1-833-331-1515.

The PMC relationship with OHCA is contractual, not governmental — PMC is NOT a state agency; it is a unit of the University of Oklahoma operating under a professional-services contract with OHCA. The University of Oklahoma College of Pharmacy is at pharmacy.ouhsc.edu.

All three SoonerSelect MCOs defer to OHCA’s PDL and PA criteria for pharmacy benefits, which means PMC’s adjudication framework applies to the entire SoonerCare population regardless of whether the member is enrolled in FFS or SoonerSelect. Oklahoma Complete Health’s pharmacy provider page states verbatim:

“Oklahoma Complete Health follows the State of Oklahoma’s preferred drug and prior authorization criteria. Some medications may require prior authorization, and some may have limitations.

Express Scripts, Oklahoma Complete Health’s PBM, processes pharmacy claims and supports pharmacy enrollment in our network.”

Note: while Oklahoma Complete Health (Centene) uses Express Scripts as its PBM for claims processing, it defers to the OHCA-defined PA criteria. The PA submission destination for all three MCOs’ members is still the OHCA Pharmacy Help Desk at 1-800-522-0114 Option 4.

7.8% SoonerCare Anti-Obesity Agent PA Approval Rate (June 2025) — Direct Evidence of the Structural Barrier

The OHCA’s quarterly DUR Board packet data provides a direct primary-source measure of how restrictive the PA framework is in practice. From the July 9, 2025 DUR Board Packet, Appendix A:

“Anti-Obesity Agents
Total: 102
Approved: 8
Denied: 77
Incomplete: 17
Average Length of Approvals (in days): 193”

That is a 7.8% approval rate (8 approved of 102 total Anti-Obesity Agent PA requests in June 2025 SoonerCare FFS). The SoonerSelect Aetna Better Health of Oklahoma data from the October 8, 2025 DUR Board Packet shows a similar result:

“Anti-Obesity Agents
Total: 72
Approved: 7
Denied: 59
Incomplete: 6
Average Length of Approvals (in days): 28”

That is a 9.7% approval rate for SoonerSelect Aetna (October 2025). These low approval rates are direct quantitative evidence that the FDA-label-restricted carve-out framework creates a structural barrier for the large majority of anti-obesity agent PA requests: most submitted requests involve drugs or indications that do not qualify under the narrow CV, MASH, OSA, or monogenic-obesity criteria.

The OHCA DUR Board Packet caveats note that the “Anti-Obesity Agents” category includes all anti-obesity drugs across the categorical exclusion — phentermine, Xenical, Saxenda, Qsymia, Contrave, Wegovy, and Zepbound are all captured in this count. The 7.8% figure is NOT a Wegovy-specific or Zepbound-specific approval rate; it reflects the combined effect of all anti-obesity agent PA activity, including drugs that are excluded entirely under OAC 317:30-5-72.1(1)(D) and would generate denials by definition.

The 193-day average approval length (June 2025 SoonerCare FFS) vs. 28-day average (October 2025 SoonerSelect Aetna) suggests significant variation depending on which indication is being approved — CV/MASH maintenance approvals (1-year approvals) would inflate the FFS average length relative to shorter titration approvals.

The T2DM Diagnosis Gate at the Operational PA Level (Added July 2025): Why Mounjaro and Ozempic Cannot Be Prescribed for Weight Loss

A critical structural enforcement mechanism in Oklahoma SoonerCare is the T2DM diagnosis gate embedded in the Anti-Diabetic Medications Tier-2, Tier-3, and Special PA Approval Criteria, updated in the July 9, 2025 DUR Board Packet. This gate operates at the operational PA level, not merely at the PDL classification level:

“Verbatim GLP-1 Agonists and GIP/GLP-1 Agonists Special PA Approval Criteria:
1. An FDA approved diagnosis of type 2 diabetes mellitus; and
2. Member must be currently stabilized on the requested product (documentation must be provided) or a patient-specific, clinically significant reason (other than convenience) why the member cannot use all available lower-tiered GLP-1 or GIP/GLP-1 agonists must be provided; and
3. Use of generic liraglutide will require a patient-specific, clinically significant reason why the member cannot use brand name Victoza® (liraglutide); and
4. A clinical exception will apply for medications with a unique FDA approved indication not covered by all Tier-2 and Tier-3 GLP-1 or GIP/GLP-1 agonists. Tier structure rules for unique FDA approved indications will apply.”

The operative sentence is criterion 1: “An FDA approved diagnosis of type 2 diabetes mellitus.” This blocks Mounjaro (tirzepatide), Ozempic (semaglutide), Trulicity (dulaglutide), Victoza (liraglutide), Rybelsus (oral semaglutide), Bydureon BCise (exenatide ER), Byetta (exenatide), Adlyxin (lixisenatide), and generic liraglutide from being approved for off-label chronic weight management — even if a prescriber submits a PA request framed as weight management.

The corresponding Tier-2 criteria state the same gate verbatim:

“Anti-Diabetic Medications Tier-2 Approval Criteria:
1. An FDA approved diagnosis of type 2 diabetes mellitus; and
2. A trial at least 3 months in duration (unless intolerable adverse effects) of metformin titrated up to maximum tolerated dose or a patient-specific, clinically significant reason why a 3-month trial of metformin titrated up to maximum tolerated dose is not appropriate must be provided.”

The clinical exception in criterion 4 of the GLP-1/GIP-GLP-1 Special PA criteria — “A clinical exception will apply for medications with a unique FDA approved indication not covered by all Tier-2 and Tier-3 GLP-1 or GIP/GLP-1 agonists” — is the regulatory hook that the OHCA used to create the standalone Wegovy CV/MASH, Zepbound OSA, and Imcivree monogenic-obesity criteria. Drugs with unique FDA-approved non-T2DM indications are administered through separate, indication-specific PA criteria rather than through the Anti-Diabetic tier structure.

The same July 2025 DUR Board Packet also updated the ADHD Medications criteria for Vyvanse (lisdexamfetamine) for Binge Eating Disorder, explicitly stating:

“Authorizations will not be granted for the purpose of weight loss without the diagnosis of BED or for the diagnosis of obesity alone. The safety and effectiveness of Vyvanse® for the treatment of obesity have not been established.”

This sentence is significant because it demonstrates that the OHCA DUR Board has explicitly considered and rejected weight-loss-purpose approvals across multiple therapeutic categories — the anti-obesity- coverage exclusion is not GLP-1-specific; it is a programmatic policy spanning the formulary.

The Three SoonerSelect MCOs: Aetna, Humana, and Oklahoma Complete Health — No Healthy Blue Oklahoma

SoonerSelect launched on April 1, 2024, following CMS approval of Oklahoma’s 1915(b) waiver in October 2023. The program covers approximately 600,000 OK Medicaid enrollees including SQ 802 expansion adults, low-income parents, pregnant women, non-disabled children, and foster care. The three medical MCOs in SoonerSelect are:

• Aetna Better Health of Oklahoma — member services 833-522-2803; Formulary Guide May 2026 (blocked from automated download but accessible via formulary search tool at aetnabetterhealth.com/oklahoma/drug-formulary.html). Contractually required to use OHCA-defined PDL and PA criteria.
• Humana Healthy Horizons in Oklahoma — member services 800-867-6601; 2026 PDL updated May 6, 2026 lists Wegovy (all strengths including oral tablets) and Zepbound at Tier 3 with PA + quantity limits — operating as the OHCA-criteria gate.
• Oklahoma Complete Health (Centene) — member services 833-522-2803; pharmacy help desk 1-833-750-3660 (SoonerSelect, 24/7); uses Express Scripts as PBM for claims processing while deferring to OHCA-defined PA criteria. February 2026 PDL lists Wegovy and Zepbound at Tier 4 (Special PA Criteria).

There is no “Healthy Blue Oklahoma” SoonerSelect plan. The 2021 Oklahoma SoonerSelect procurement included Blue Cross Blue Shield of Oklahoma (BCBSOK) and UnitedHealthcare as initially selected plans, but the procurement was invalidated by the Oklahoma Supreme Court. BCBSOK and UnitedHealthcare are NOT current SoonerSelect MCOs as of 2026. Any reference to Healthy Blue Oklahoma in pre-2024 materials is outdated.

The verbatim Oklahoma Complete Health PDL header (February 2026) lists “Weight loss or weight gain” as one of the drug categories “not part of the benefit”:

“Which drug categories are not covered by the Preferred Drug List?
The following drug categories are not part of the benefit:
• Fertility drugs
• Weight loss or weight gain
• Drug Efficacy Study Implementation (DESI). These are drugs that are not shown to be safe and effective.
• Bulk chemicals/powders
• Experimental and investigational drugs
• Drugs and devices not approved by the FDA”

Humana’s 2026 OK PDL verbatim entry for Wegovy:

“WEGOVY 0.25 MG/0.5 ML SUBCUTANEOUS PEN INJECTOR — Tier 3 — PA, QL(2 per 28 days)
WEGOVY 1.5 MG TABLET — Tier 3 — PA, QL(30 per 30 days)
WEGOVY 2.4 MG/0.75 ML SUBCUTANEOUS PEN INJECTOR — Tier 3 — PA, QL(3 per 28 days)
ZEPBOUND 10 MG/0.5 ML SUBCUTANEOUS PEN INJECTOR — Tier 3 — PA, QL(2 per 28 days)”

Tier 3 with PA means the drug is accessible only through the OHCA- defined PA criteria — the FDA-label-restricted carve-outs. A Humana SoonerSelect member submitting a Wegovy PA for chronic weight management will receive the same FDA-label-restricted denial as a SoonerCare FFS member.

PHARM-277: The Operationally-Binding Wegovy PA Form (Revised April 16, 2026)

The document that providers actually fax to OHCA/PMC to obtain a Wegovy PA is OHCA Pharmacy Form PHARM-277, revised April 16, 2026. This form covers BOTH the CV indication AND the MASH indication on a single document, with check-box logic for which indication applies. The verbatim instructions from Page 1 of the PHARM-277 form:

“State of Oklahoma SoonerCare®
Wegovy (semaglutide) Prior Authorization Form

Criteria For Initial Authorization (Page 1 of 2)

1. Does the member have type 1 diabetes mellitus (T1DM) or type 2 diabetes mellitus (T2DM)? Yes___ No___
2. Will member use Wegovy® in combination with other semaglutide-containing products or any other glucagon-like peptide-1 (GLP-1) receptor agonist? Yes___ No___
3. Will Wegovy® be used in conjunction with diet and exercise? Yes___ No___ [clinical documentation (i.e. office notes) of this discussion with the member must be included with the request]
4. Please indicate the diagnosis and information:
  ☐ To reduce the risk of major adverse cardiovascular (CV) events
    a. Does the member have established cardiovascular disease (CVD)? Yes___ No___
    b. Is the member obese or overweight? Yes___ No___
    c. Does the member have a history of any of the following? (Check all that apply and clinical documentation must be submitted with the request)
      ☐ Previous myocardial infarction
      ☐ Previous stroke
      ☐ Symptomatic peripheral arterial disease confirmed by 1 of the following:
        ☐ Intermittent claudication with ankle-brachial index <0.85 at rest
        ☐ Peripheral arterial revascularization procedure
        ☐ Amputation due to atherosclerotic disease
    d. Member’s body mass index (BMI): _____ Date Taken: _____
    e. Member’s hemoglobin A1C (HbA1c): _____ Date Taken: _____
    f. Is the member currently receiving guideline-directed management and therapy (GDMT) for CVD? Yes___ No___”

The MASH section on Page 2 covers: noncirrhotic MASH confirmation, F2/F3 fibrosis test results (FibroScan VCTE, ELF, or liver biopsy), chronic liver disease exclusion, metabolic comorbidity management attestation, and the gastroenterologist/hepatologist prescription confirmation.

The form concludes with the submission address:

“PLEASE PROVIDE THE INFORMATION REQUESTED AND RETURN TO:
University of Oklahoma College of Pharmacy
Pharmacy Management Consultants
Product Based Prior Authorization Unit
Fax: 1-800-224-4014
Phone: 1-800-522-0114 Option 4
Pharm-277  4/16/2026”

As of 2026-05-10, no equivalent standalone PHARM form exists for Zepbound OSA or Imcivree. The OHCA Pharmacy Forms page at oklahoma.gov/ohca/providers/forms/rxforms.html should be checked for any subsequently published forms.

HJR 1067 + HB 4440: The 2026 Medicaid-Expansion Defunding Ballot Measures — Out of GLP-1 Coverage Scope

The dominant Oklahoma Medicaid legislative activity in the 2026 Regular Session involves HJR 1067 (Rep. Ryan Eaves / Sen. Julie Daniels) and HB 4440 (Rep. Eaves) — both proposing ballot measures related to the SQ 802 Medicaid expansion. HJR 1067 would place a state question on the November 2026 general election ballot that would amend SQ 802 to allow future legislatures to choose NOT to fund Medicaid expansion if the federal matching rate (FMAP) falls below 90%. HB 4440 would move the expansion language from the Oklahoma Constitution to statute, allowing modification or termination by simple majority vote.

Neither bill addresses GLP-1 coverage. Both are about the underlying program funding structure, not the formulary content. A search of the Oklahoma Legislature bill portal at oklegislature.gov for “GLP-1,” “obesity,” and “weight loss” returned no proposed coverage-mandate or coverage-restriction bills in the 2025 or 2026 Regular Sessions. Oklahoma’s GLP-1 policy is being shaped through DUR Board PA-criteria votes rather than through legislation.

If HJR 1067 passes and the SQ 802 expansion is subsequently rolled back through a future ballot measure or legislative action, the population eligible for any SoonerCare GLP-1 coverage — including the FDA-label-restricted carve-outs — would shrink materially. This is a structural fiscal-context point, not a prediction. As of 2026-05-10, Oklahoma remains an expansion state with approximately 600,000 SoonerSelect enrollees.

T2D vs. Chronic Weight Management: The Coverage Boundary That Most Members Miss

The coverage boundary in Oklahoma SoonerCare has two layers that are frequently confused by patients and providers:

Layer 1 — The PDL / Administrative Code level: OAC 317:30-5-72.1(1)(D) bars chronic-weight-management drugs categorically. Wegovy, Saxenda, Qsymia, Contrave, phentermine, orlistat, and Foundayo (orforglipron) do not have an approved pathway for the chronic-weight-management indication (Wegovy has two non-weight-loss carve-outs; the others have none).

Layer 2 — The operational T2DM gate: GLP-1 receptor agonists that ARE on the OHCA PDL (Trulicity, Ozempic, Victoza, Rybelsus, Mounjaro, Bydureon BCise, Byetta, Adlyxin) are gated on “An FDA approved diagnosis of type 2 diabetes mellitus.” A prescriber who submits a Mounjaro PA for a member with obesity but without T2DM will receive a denial not because Mounjaro is absent from the PDL, but because the PA criteria require a T2DM diagnosis.

The practical implication: a SoonerCare member with obesity and T2DM can obtain Ozempic or Trulicity for T2DM treatment via the Anti-Diabetic Medications Tier-2 pathway. A SoonerCare member with obesity but WITHOUT T2DM has only four possible pathways: (1) Wegovy CV carve-out if they have established CVD and meet the 13-criterion PA criteria; (2) Wegovy MASH carve-out if they have noncirrhotic MASH F2/F3; (3) Zepbound OSA carve-out if they have moderate-to-severe OSA (AHI ≥ 15) and obesity; or (4) Imcivree if they have POMC/PCSK1/LEPR deficiency or BBS. None of these pathways reaches the general-population chronic-weight-management indication.

Oklahoma in the 24-State Taxonomy: Comparison With Prior States

Among the 24 states analyzed in this series, Oklahoma’s structural posture is most analogous to Kentucky (Pattern #21) and Alabama (Pattern #23), but with three structural differences:

Oklahoma’s four carve-outs (Wegovy CV + Wegovy MASH + Zepbound OSA + Imcivree) exceed both Alabama (2 carve-outs) and Kentucky (3 carve-outs), making Oklahoma the highest carve-out count in the categorical-exclusion cluster to date. However, all three states share the same fundamental structural posture: categorical exclusion of chronic-weight-management GLP-1 coverage, with narrow FDA-label-restricted exceptions.

Excluded Populations and Out-of-Scope Programs: EGID HealthChoice and SoonerCare Fee-for-Service Categories

Several Oklahoma health benefit programs are structurally separate from SoonerCare and must not be confused with it:

EGID HealthChoice (State Employee Plan) — NOT SoonerCare: The Employees Group Insurance Division (EGID) is a division of OHCA that administers HealthChoice — the health plan for state employees, education employees, local government employees, retirees, and dependents. HealthChoice 2025 plan documents reference Wegovy, Zepbound, Saxenda, and the broader GLP-1 class. However, specific PA criteria, BMI thresholds, T2DM gates, or weight-loss carve-outs under HealthChoice are [NOT VERIFIED in this article’s source brief]. This article covers SoonerCare/SoonerSelect only. Members seeking HealthChoice GLP-1 coverage information should contact EGID HealthChoice member services directly.

SoonerCare FFS vs. SoonerSelect enrollment: As of April 1, 2024, approximately 600,000 OK Medicaid enrollees are in SoonerSelect (managed care). Aged/blind/disabled (ABD) members, dual-eligibles, Insure Oklahoma members, and other categorical eligibles remain in SoonerCare Fee-for-Service. Both populations are governed by the OHCA PDL and PA criteria — the distinction is administrative (FFS vs. managed care), not coverage-based. Dual-eligible members (those eligible for both Medicare and Medicaid) may have Medicare Part D as the primary pharmacy payer; Medicare Part D covers GLP-1s for T2DM but applies variable coverage rules for the chronic-weight-management indication.

Patient Action Steps and Appeal Pathway (OHCA Hearings Office)

Based on the verified criteria above, here are the actionable steps for SoonerCare members:

If you have established CVD (prior MI, stroke, or symptomatic PAD) and overweight/obesity but NO T2DM:

1. Ask your prescriber to submit a Wegovy PA using PHARM-277 (download from oklahoma.gov/ohca/providers/forms/rxforms.html).
2. Ensure the form includes: BMI and date, A1C and date, GDMT documentation, and CVD history (MI/stroke/PAD documentation).
3. Fax PHARM-277 to 1-800-224-4014. Initial titration approvals are 8 weeks per dose.

If you have noncirrhotic MASH with confirmed F2/F3 fibrosis and NO T2DM:

1. Obtain FibroScan (VCTE ≥ 8kPa + CAP ≥ 280) or ELF (≥ 9) or liver biopsy (F2/F3) results.
2. Get a prescription from, or documentation of consultation with, a gastroenterologist or hepatologist.
3. Submit PHARM-277 (MASH section, Page 2) to fax 1-800-224-4014. Initial titration approvals are 8 weeks per dose.

If you have moderate-to-severe OSA (AHI ≥ 15) and obesity (BMI ≥ 30) but NO T2DM:

1. Obtain polysomnography (PSG) or HSAT documentation with the AHI value.
2. Call the OHCA Pharmacy Help Desk at 1-800-522-0114 Option 4 to confirm the current Zepbound PA submission form (no standalone PHARM-XXX was published as of 2026-05-10).
3. Submit the PA with AHI value, BMI, and A1C (< 6.5% required).

If your PA is denied:

• SoonerCare FFS members: File an LD-1 Member Complaint/Grievance Form with OHCA within 30 calendar days of the denial notice. Per OAC 317:2-1-2(a): “A fair hearing before the OHCA ALJ (Administrative Law Judge) will be scheduled. A decision is normally rendered by the OHCA ALJ within twenty (20) days of the hearing.”
• SoonerSelect MCO members: First exhaust the MCO internal appeal (Aetna: 833-522-2803; Humana: 800-867-6601; Oklahoma Complete Health pharmacy appeals: 888-865-6531). After exhausting the MCO appeal, request a Medicaid State Fair Hearing within 120 calendar days of the MCO appeal decision. Per the SoonerSelect Member Rights guidelines: “If you do not agree with an appeal decision, you have the right to request a Medicaid State Fair Hearing.”

Important limitation on the appeal pathway: The OHCA fair hearing process is unlikely to overturn a properly-applied PA denial because the PA criteria are themselves the operative coverage rule. A Wegovy CV-only denial for a member who lacks established CVD will be upheld on appeal because the criteria do not authorize coverage absent CVD. The appeal process is appropriate for procedural errors (wrong criteria applied, missing documentation that was actually submitted, etc.) — not for expanding the coverage framework beyond what the DUR Board has approved.

For members who do not qualify under any carve-out (the overwhelming majority): Cash-pay compounded semaglutide and tirzepatide from licensed 503A/503B pharmacies, and brand-name Wegovy through the NovoCare patient-access program, are the primary alternative pathways. See the GLP-1 Pricing Index for current cash-pay channel pricing across 70+ providers — the 7.8% approval rate in Oklahoma means the 92.2% of applicants who are denied represent a structural cash-pay demand pool.

Related Research

• Alabama Medicaid GLP-1 Coverage (2026): Pattern #23 — PDL-Enumerated Zepbound OSA Carve-Out + Wegovy via Cardiac Agents PA — Alabama is Oklahoma’s closest analog in the categorical- exclusion cluster. Both have Zepbound OSA and Wegovy MACE carve-outs anchored in state administrative code, but Oklahoma adds Wegovy MASH and Imcivree monogenic-obesity for 4 total carve-outs vs. Alabama’s 2. Alabama uses Acentra Health (national PBM); Oklahoma uses OU College of Pharmacy / PMC (unique in series). Alabama is a non-expansion state; Oklahoma expanded via SQ 802 in July 2021.
• Kentucky Medicaid GLP-1 Coverage (2026): Pattern #21 — Nullified-Amendment Exclusion State with Wegovy MACE/MASH + Zepbound OSA Carve-Outs — Kentucky has 3 DUR-board-aligned carve-outs (Wegovy MACE, Wegovy MASH, Zepbound OSA) administered through MedImpact PA criteria. Oklahoma extends to 4 carve-outs by adding the Imcivree monogenic- obesity pathway — the only state in this series to document Imcivree at the DUR-board PA-criteria level. Both states use university- affiliated healthcare systems but KY uses a national PBM while OK uses OU-College-of-Pharmacy administration directly.
• GLP-1 Pricing Index — Current Cash-Pay Rates Across 70+ Providers (Updated Monthly) — Oklahoma’s 7.8% anti-obesity agent PA approval rate (June 2025 SoonerCare FFS) means approximately 92.2% of PA applicants are denied and must seek alternative coverage or cash-pay pathways. This index tracks compounded semaglutide ($99–$400/month), compounded tirzepatide, brand-name Wegovy via NovoCare ($299/month), and GoodRx channels — updated monthly.
• GLP-1 Side Effects: Questions Answered (Nausea, Fatigue, Hair Loss, and More) — For patients who obtain Wegovy or Zepbound through one of Oklahoma’s narrow carve-out pathways or through cash-pay channels, this comprehensive Q&A covers the common adverse effects documented in the SELECT, SURMOUNT-OSA, and ESSENCE trials.

Last Verified Date and Primary Sources

Last verified: 2026-05-10. This article should be re-verified against the OHCA DUR Board meeting packets (published monthly at oklahoma.gov/ohca/about/boards-and-committees/drug- utilization-review/dur-board-meeting-agendas.html) and the OHCA Pharmacy Forms page (oklahoma.gov/ohca/providers/forms/rxforms.html) whenever a new DUR Board packet is published. The PHARM-277 form is currently dated 4/16/2026; a subsequent revision may supersede it. No Zepbound standalone PHARM form was published as of 2026-05-10. HJR 1067 / HB 4440 status was “in committee” as of 2026-05-10 — these bills may move before the 2026 Regular Session adjourns.

The closest state-series analog to Oklahoma's triple-carve-out + university-pharmacy-DUR architecture is Colorado Medicaid (Health First Colorado / Pattern #27) — which shares the same categorical regulatory exclusion structure (10 CCR 2505-10 § 8.800.4.B.2.a vs. OAC 317:30-5-72.1(1)(D)) and the same three DUR-Board-approved FDA-label carve-outs (Wegovy CV, Wegovy MASH, Zepbound OSA). Colorado's DUR Board is also administered through a state university (University of Colorado Skaggs School of Pharmacy, SSPPS.co-dur@cuanschutz.edu) — the only other state in the 27-state series to share this university-DUR governance structure. Key differences: Colorado's BMI threshold for Wegovy CV is BMI ≥ 25 (more permissive than Oklahoma's BMI ≥ 27); Colorado does NOT have an Imcivree monogenic-obesity carve-out (unique to OK in the 27-state series); Colorado's university role is limited to DUR Board governance while Oklahoma's OU/PMC administers PA criteria drafting and adjudication; and Colorado passed SB 25-048, a large-group commercial anti-obesity coverage mandate (effective January 1, 2027), with its Medicaid program deliberately excluded — a legislative maneuver with no Oklahoma parallel.

A second university-PA-infrastructure parallel is Louisiana Medicaid (Healthy Louisiana / Pattern #28) — the only other state in the 28-state series with a state-university-administered FFS pharmacy PA infrastructure. Louisiana's ULM (University of Louisiana at Monroe) College of Pharmacy Prior Approval Desk administers FFS PA adjudication (Gainwell Technologies BIN 610514), paralleling Oklahoma's OU/PMC model. Louisiana shares Wegovy CV-only and Zepbound OSA-only criteria content with Oklahoma, but differs structurally: Louisiana enumerates both drugs on its Single PDL with PATIENT TREATMENT AGREEMENT notation; Louisiana does not have Wegovy MASH-only or Imcivree monogenic-obesity carve-outs (unique to OK). And Louisiana's 2026 legislative trajectory is an active expansion push — SB 433 passed Senate 31-0 on April 29, 2026 (House pending, Jan 1, 2027 effective date) — rather than Oklahoma's stable exclusion posture.