ASHP Stands Opposed to Payer-Mandated White Bagging

ASHP and our member leaders from the Pharmacy Executive Leadership Alliance (PELA) Advisory Panel, the Section of Pharmacy Practice Leaders (SPPL), and the Section of Specialty Pharmacy Practitioners are working to address the rapidly growing trend of payer-mandated white bagging for clinician-administered medications. These members have coordinated an advocacy agenda and resources for health-system pharmacy to address this increasingly untenable practice.

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.

ASHP is taking extensive action to address payer-mandated white bagging. In addition to directly lobbying the federal government to act, ASHP is engaging with health systems, peer organizations, and state affiliates, as well as mobilizing our members. Our efforts include:

• Co-signing a letter to the Food and Drug Administration with more than 50 health systems outlining our shared concern that payer-mandated white bagging threatens patient safety by circumventing Drug Supply Chain Security Act reporting requirements and depriving providers of essential pedigree information for the drugs they administer to their patients.
• Leveraging PELA and SPPL to host a series of virtual roundtables with health-system pharmacy executives throughout March. These roundtables serve as a forum for health-system leaders to describe and discuss various aspects of payer-mandated white bagging, which poses challenges to patient safety, clinical operations, and compliance with state and federal regulations.
• Developing and sharing a self-assessment checklist tool to assist health-system leaders in appraising a common set of evaluation points and further informing discussions with peers and affiliate organizations. 
• Supporting state advocacy efforts through engagement with our state affiliates, including a State Legislative Network “Policy Deep Dive” webinar to be held in April that will highlight state efforts to enact legislation and induce action from boards of pharmacy to directly address payer-mandated white bagging.
• Planning for additional ASHP member webinars addressing advocacy, best practices on reducing risks resulting from white bagging, and solutions to minimize impact of white bagging. We also recently published an ASHP podcast on white bagging advocacy that provided an overview of payer-mandated white bagging and its impact on health systems.
• Partnering with the American Hospital Association to develop educational resources and joint advocacy initiatives to oppose payer-mandated white bagging.

Health systems are committed to providing patients with the highest quality of collaborative multidisciplinary healthcare in an environment that enables swift and nimble selection of the most appropriate therapy at the correct dose. Unfortunately, increasingly frequent and restrictive payer-mandated white bagging of clinician-administered medications is unnecessarily threatening those commitments.

ASHP will keep members updated on upcoming webinars and member opportunities to engage in our advocacy efforts. ASHP encourages members to submit additional insights and concerns on payer-mandated white bagging of medications to [email protected].