White Bagging: Emerging Trends, Provider Response, and Implications for Reimbursement

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.

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.