A recently emerging trend among payers seeks to replace the buy and bill system with a “white bagging” acquisition system. In essence, this transfers the process from the medical side of insurance to the pharmacy side. This policy mandates that physicians receive the medication from a specialty pharmacy, which will be shipped to their office for administration.
Under this model, practices are forced to accept medications that are not controlled by the practice and wholesaler’s drug supply chain security and quality-control measures, which guarantee safety of administration.
Under the white bagging model, practices do not have control over the handling, preparation, and storage conditions of the drug prior to its administration. Improper handling on the part of a specialty pharmacy can have serious consequences for patients, and white bagging removes practices’ ability to prevent adverse events through internal oversight.
Patients are going to face delays in treatment and unnecessary hardships, as compared to the practice sourcing medication from its own inventory for in-office administration. While practices’ responsibility for much of the pre-administration handling is removed under the white bagging model, their liability is not. Practices may still be held liable for adverse events that occur because of circumstances they no longer control under a white bagging model.
The Coalition of State Rheumatology Organizations (CSRO) is opposed to mandatory use of the white-bagging acquisition system by payers for their members.
In response to this recent trend, CSRO has launched a grassroots campaign to support legislative and regulatory policies that ban specialty pharmacy mandates that impact the rheumatology community. This includes drafting model language, building and joining state coalitions, submitting communications to media outlets, posting to social media, providing committee testimony, creating action alerts for members, and other grassroots advocacy activities.
CSRO also has published a template letter for practices to use in addressing white bagging mandates with insurers, which includes a release of liability form to put the responsibility on the specialty pharmacy – not the provider.
Visit our Legislative Map Tool to read about current white bagging ban laws or legislation in your state. You can send letters in support of pending legislation and find educational materials.