Dear Ms. Yeatts:

The Virginia Association of Hematology and Oncology (VAHO) appreciates this opportunity to comment on the Virginia Board of Pharmacy’s (the “Board”) Notice of Intended Regulatory Action to amend 18VAC110-20, Regulations Governing the Practice of Pharmacy, regarding the “white bagging” and “brown bagging” of drugs. VAHO represents over 150 oncology physicians and other oncology healthcare professionals practicing in Virginia.  VAHO seeks to improve the quality of oncology care available to the people of Virginia. VAHO members are committed to ensuring that safe, evidenced-based practices for the prevention, diagnosis and treatment of cancer are available to all Virginians. 

Under the definition of the National Associations of Boards of Pharmacies (NABP), VAHO recognizes “white bagging” and “brown bagging” as the following:

• “Brown Bagging” – Under this practice, a pharmacy dispenses a medication directly to a patient, who then transports the medication themselves for administration at their physician’s office. Often, this practice occurs at specialty pharmacies.
• “White Bagging” – Under this practice, the pharmacy dispenses a patient’s medication to the physician’s office for administration. This practice is often used for oncology patients to obtain medications that are not available at all non-specialty pharmacies.

Administration of drugs for cancer patients requires a great deal of care and sensitivity to ensure safety for the patient and provider. Due to the imperative needs of oncology drugs to be treated with certain handling, storage, and transportation requirements, VAHO is deeply concerned and opposes brown bagging to deliver injectable oncolytics to cancer patients in the state of Virginia. Both white bagging and brown bagging have the potential to put the patient and their provider at risk, as well as significantly impact a patient's treatment outcomes, and for that reason, VAHO stands in opposition of the NAIRO notice. Oncology drugs are delivered to patients specifically with adequate safety measures in mind, especially during administration. 

VAHO would like to voice concern over a waste issue that can arise with "white bagging" if a physician needs to make a timely decision to update a patient's dosage or adjustment of a patient's treatment. Administration of oncolytics for a patient can change rapidly, and "white bagging" has been proven to increase waster of expensive oncolytics for cancer patients and their providers across the country. 

Thank you for this opportunity to share the oncology provider perspective on your proposals in the Virginia Board of Pharmacy’s Notice of Intended Regulatory Action to amend 18VAC110-20, Regulations Governing the Practice of Pharmacy, regarding the “white bagging” and “brown bagging” of drugs. VAHO supports continued consideration of these regulations but is in strong opposition to “white bagging” and “brown bagging.” Please feel free to contact Dr. Richard Ingram, VAHO President, if you have any questions or need any additional information.  We look forward to working with you on this critical issue for oncology patients and their providers in the state of Virginia. Thank you again for your attention to this very important matter.

Respectfully Submitted, 

Richard Ingram, MD

VAHO President