About the Course
Introduction
This CLE webinar will guide healthcare counsel on white bagging and how different healthcare providers are responding to white bagging mandates. The panel will address white bagging in the litigation context and discuss how white bagging impacts regulatory compliance.
Description
White bagging is a practice involving healthcare providers (such as doctors, clinics, and hospitals) and pharmacies, whereby a patient's medication to be used in a procedure is sent directly by the pharmacy to the provider for administration to the patient. Many payers, primarily large national insurers, have recently begun to mandate white bagging by requiring that in-office administered medications be purchased and dispensed through the payers' wholly owned or affiliated pharmacies, as opposed to being sourced and provided directly by the administering provider. Healthcare providers are then expected to receive and administer this medication filled and dispensed by the payer-owned pharmacy.
While payers have suggested that white bagging helps control costs based on the site of care, it also bypasses many of the healthcare system's checks and balances, such as pharmacy formularies, checking of drug interactions, and safety protocols. This practice also puts at risk medication and supply chain integrity, as well as patient safety.
As insurers are implementing mandatory white bagging policies for certain medications, healthcare systems and providers must prepare to address the issues created by these policies. Further, they need to be ready to address these concerns through both regulatory compliance and litigation.
Listen as our authoritative panel of healthcare attorneys examines white bagging and how different healthcare providers respond to white bagging policies. The panel will address white bagging in the litigation context—both how the courts address the issues and litigation strategies. The panel will also discuss how white bagging impacts contract negotiations. Finally, the panel will examine the implications of white bagging on 340B participation and will explore mitigation strategies that have been pursued by healthcare providers.
Presented By
Mr. Dresser, Esq. is a Partner in Frier Levitt’s Life Sciences Department and heads the firm’s Pharmacy Practice Group. His practice is dedicated to representing a broad cross-section of pharmacies and pharmacy providers, including community retail pharmacies, chain pharmacies, compounding pharmacies, specialty pharmacies, mail order pharmacies, home infusion providers, and dispensing physician practices. Jesse represents pharmacy providers nationally on issues with payors and Pharmacy Benefit Managers (PBMs), including PBM audit appeals, network terminations, network access and credentialing applications, and reimbursement issues. In addition to his work with pharmacy clients, Mr. Dresser also represents a variety of other entities across the healthcare and life sciences spectrum, including other healthcare providers, pharmaceutical and biotech manufacturers, pharmaceutical wholesalers and distributors, and healthcare technology companies. Through this work, he has focused on the intersection between the law and economic considerations, including drug pricing, marketing techniques, and benefits management. Mr. Dresser frequently lectures across the country at national and regional pharmacy and healthcare conferences and organizations, including the International Academy of Compounding Pharmacists (IACP), the American College of Apothecaries (ACA), the American College of Veterinary Pharmacists (ACVP), the National Association of Specialty Pharmacy (NASP), the Community Oncology Alliance (COA) the Community Oncology Pharmacy Association (COPA), the National Home Infusion Association (NHIA), and the Immunoglobulin National Society (IgNS). He also regularly hosts pharmacy industry webinars for a variety of industry organizations and affiliated companies.
Ms. Gordon’s practice centers on managed care litigation in counseling providers, hospital systems, and device manufacturers in disputes over benefit determination, medical necessity denials, contract interpretation, and in- and out-of-network reimbursement. With over 15 years of litigation experience, she is well-versed in providing tailored strategic solutions to represent clients in the ever-changing landscape of healthcare litigation. Ms. Gordon’s representative work includes resolving disputes between healthcare companies and health plans regarding coverage and reimbursement disputes. She has noteworthy experience representing hospital systems and medical device manufacturers in disputes regarding underpayments and denials due to medical necessity, experimental/investigational designations, recoupments/offsets, DRG downgrades, billing and coding audits, including not-separately reimbursable line-item charge denials, as well as unilateral payor policies involving E/M downcoding, Sepsis-3, white-bagging, Covid-19 reimbursement, site-of-service coverage, and other policies resulting in a reduction of reimbursement and an increase in administrative burden.
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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Date + Time
- event
Thursday, March 5, 2026
- schedule
1:00 p.m. ET./10:00 a.m. PT
I. White bagging: what is it?
II. Healthcare provider response
III. Court treatment and litigation strategies
IV. Implications for contract negotiations
V. Impact on the 340B program
VI. Mitigation strategies
The panel will review these and other important questions:
- What impact do white bagging policies have on the provider's ability to seek reimbursement for these medications?
- What measures should healthcare providers take to mitigate the risks created by mandatory white bagging?
- What can providers do to ensure indemnification for accepting white-bagged medications?
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