Thank you for the opportunity to comment on proposed regulation related to the practice of white bagging/brown bagging.  Many insurance providers/pharmacy benefit managers are disrupting the traditional patient-provider relationship, adding increased burden to the provider and patient, and potentially jeopardizing the integrity of medication and provision of timely patient care through the mandate to have medications supplied through a "white bag" or "brown bag" process.  Overall, I agree with the regulation language, and specifically with the changes that allow for exemptions for certain circumstances. 

Within many health systems, the pharmacy department routinely provides purchasing oversight for hospital owned clinics.  For health systems, such as ours, where there is a specialty pharmacy presence, we attempt to practice "clear bagging" where the medication is filled through an organization owned pharmacy and delivered to the provider location using organization resources and tracking.  Based on the language under (F) related to "the alternate delivery site does not routinely receive delivery form the pharmacy, I wanted to make sure that this practice of "clear bagging" would not be at risk nor would require that we register every physician clinic with a BOP CSR or practitioner of the healing arts license to sell controlled substance registration. 

Additionally, I would suggest some type of phase in period for the regulation to allow adequate time for notification to providers, patients and payers in order to not disrupt care.

Thank you