Agencies | Governor
Virginia Regulatory Town Hall
Department of Health Professions
Board of Pharmacy
Regulations Governing the Practice of Pharmacy [18 VAC 110 ‑ 20]
Action Brown bagging and white bagging
Comment Period Ends 9/5/2018
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9/4/18  12:28 pm
Commenter: Elizabeth Early

White/Brown bagging

I believe that brown bagging should not be allowed for the simple reason of that the pharmacy has to control of the medication to ensure the appropriate storage and integrity of the medication.  We cannot delegate this responsibility, not even to the patient.

As for white bagging, I also do not support the use of white bagging for a facility that is capable of providing the medication for their patients.  The reasons for not supporting this practice based on a variety of quality and patient safety issues.  My concerns are:   

  • Patients receive a call from a pharmacy that is unknown to them and may be asked to provide credit card information to a company not associated with facility providing the care (difficult to differentiate from a phone scam).  This may cause a delay in treatment.
  • Before a shipment is sent out, the mail order pharmacy requires the approval and full copay remittance from the patient: no monthly payments or bills after the treatment as you would find at a healthcare facility.  Due to the high cost and co-pays for these medications, this may cause a significant financial burden and/or result in a delay in treatment. 
  • The patient’s next treatment becomes dependent on a delivery, not an established schedule. Coordinating ordering, receipt and administration drains a facility’s resources and may test the staff’s (and the patient’s) patience.
  • The mail order pharmacy will not have the entire medical record for the patient which may lead to issues with continuity of care between the ordering provider, the pharmacy and the facility infusing the medication. 
  • The patient’s condition may change before the shipment is received. The patient may have to pay for another medication (in addition to the one that was sent originally).  Because the drug arrives at the facility, but is the property of the patient, the pharmacy cannot use the drug on another patient and is now responsible for disposal of a hazardous product.
  • Most mail order pharmacies are not willing to sign alternate site delivery contracts as required by Virginia law. 
  • The origin of drugs cannot be traced further back than the mail-order company. Where, when and from whom were the drugs purchased?
  • Mail order pharmacies may take longer to fill backorders causing delays and cancelling treatments that may be perceived by the patient as a facility issue. 
  • A delivery may sit for hours in extreme heat or cold conditions.  So, a box full of sensitive drugs sitting outside for hours may result in compromised contents….how does the facility ensure that it was handled appropriately and safely at all times if they are not controlling the supply chain?
  • Is the facility legally responsible for any product injected into the patient even when they have lost control of the process? Will malpractice insurance cover such claims? Whose fault is it in the case of a negative outcome?
  • The pharmacy preparing the drug receives no reimbursement for their time and supplies used to get the drug ready for administration.  In addition, the facility may not be able to get reimbursement/denied reimbursement for the administration if there is no drug charge on the bill. 
CommentID: 66954