During a session at Specialty Pharmacy Next 2023, Jorge Garcia, PharmD, assistant vice president, Baptist Health Cancer Care, and Kenneth Komorny, PharmD, vice president, chief pharmacy officer, Moffitt Cancer Center, discussed white and brown drug bagging as well as the impact of these mandates.

According to the speakers, there are three different type of drug bagging, including brown; white; and clear.

The different drug bagging types are defined as the following:

• Brown Bagging: Dispensing patient-specific medication(s) from health plan’s preferred pharmacy directly to a patient, who then transfers the medication(s) to a medical practice for administration
• White Bagging: Distribution of patient-specific medication(s) from health plan’s preferred pharmacy to the physician’s office, hospital, or clinic for administration
• Clear Bagging: Dispensing patient-specific medication(s) from provider pharmacy under common ownership to the physician’s office, hospital, or clinic for administration

According to the session, there are multiple concerns that are linked with to drug bagging. They explained there are concerns linked to supply chain custody and integrity, bypassing safety checks, systemic treatment delays, and increased unmitigated clinical and economic burdens for providers. All these concerns ultimately impact the patient experience, adherence, and clinical outcomes.

In addition to these overall concerns, there are also operational challenges with drug bagging. Dr Garcia explained that there are increased operating costs and many uncompensated services.

According to results of the Pharmacy Provider National survey, 268 respondents experienced the following linked to drug bagging:

• 83% – Product did not arrive in time for patient administration;
• 66% – Product received was no longer correct due to updated patient treatment course or dose being changed;
• 42% – Product delivered as inappropriate / wrong dose;
• 43% – Product not built in computer system;
• 37% – Product delivered was damaged; 
• 95% – Respondents experience operational and safety issues.

Aside from the general concerns identified in the survey, Dr Garcia also said It causes a disruption of the 340B drug program. They explained that both white and brown bagging allow an insurer to control the distribution of drugs and eliminates the 340B benefit to the provider. Further, it “undermines the intent of the 340B Drug Pricing Program.”

Following the concerns, the session then covered advocacy options for pharmacies. Currently there are multiple states focusing on their Board of Pharmacy Rules. Although others are emerging, Texas, Virginia, California, Missouri, and Washington are current states reviewing their rules.

“How can you protect your patients,” Dr Garcia asked. He explained that aside from joining advocacy efforts, pharmacists and pharmacies can establish institutional polices, notify manufacturers that you were not able to prescribe their drug, consider escalating concerns to regulatory bodies, or “collaborate with internal managed care partners to assess if white bagging mandates are enforceable.”