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
Stage Final
Comment Period Ended on 6/9/2021
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6/7/21  1:10 pm
Commenter: Mark Hickman, Virginia Society of Health-System Pharmacists (VSHP)

VSHP Comment on White/Brown Bagging

The Virginia Society of Health-System Pharmacists (VSHP) submits the following public comment:


VSHP supports the goal of the proposed regulations which were developed, including VSHP comment provided at the time, as a positive first step in setting up guard rails in anticipation of this emerging practice. Payors recently implemented additional, specific white bagging policies that have added to the challenges and burden posed by current white bagging practices that prevent providers from timely and optimized care.

The implementation of actual payor policies has revealed serious patient safety and hospital pharmacy operational concerns, many of which our colleagues at the Virginia Hospital and Healthcare Association (VHHA) outline in their letter dated May 21, 2021 submitted as public comment, with which we associate ourselves.


While we are aware at this time of certain temporary delays in implementation of payor specialty pharmacy policy, we note that the delay is from only one payor and can be ended at any time, and that other existing policies and practices of concern have been and are still in place. 


We also note that current white bagging practices do not allow for the kind of flexibility, adjustments, supply chain processes, and safety procedures used by hospital systems to help avoid waste and ensure drug integrity for the patient.


VSHP aligns itself with the American Society of Health System Pharmacists (ASHP) white bagging statement:


ASHP stands opposed to payer-mandated white bagging models that jeopardize optimal, safe, and effective medication use. It is ASHP’s position that payer-mandated distribution models that require clinician-administered drugs to be dispensed exclusively via third-party specialty pharmacies are placing patients at risk and threaten to compromise organizations’ well-established practices intended to ensure patient safety. Additionally, white bagging negatively impacts pharmacists’ ability to validate medication integrity and maintain oversight of storage and handling. Further, by sidestepping well-established supply chain procedures, white bagging disrupts efforts to maintain adherence with protocols designed to ensure patient safety, quality, and continuity of care.


We do continue to support the “brown bagging” component of the proposed regulations, and we also reserve the opportunity to evaluate brown bagging policies and practices as they continue to emerge.


VSHP supports the Board of Pharmacy’s decision taken at its June 4, 2021 meeting to issue a Guidance Document clarifying the meaning of routine delivery and compliance with existing regulations. We look forward to engaging in the guidance development process.

We encourage the Board of Pharmacy to continue to monitor the proliferation of payor white bagging policies and their impact on patient safety to determine whether a reevaluation of relevant regulations may be necessary in the future. 


Thank you for your consideration.

CommentID: 98962