The Illinois Council of Health-System Pharmacists (ICHP) supports healthcare organizations in not allowing “white/brown bagging” except in an emergency situation.

“White/brown bagging” is the practice of having patient specific medications or supplies provided by another pharmacy which may be brought in by the patient or delivered directly to the practice site for administration.  Often times these medications may need further preparation or compounding by the practice site prior to administration.  Most of these medications are expensive injectable medications used to treat chronic diseases such as osteoporosis, multiple sclerosis, cancer, and rheumatoid arthritis.

ICHP recognizes the regulatory and safety issues related to the practice of re-dispensing medications provided by another pharmacy.  The use of these types of medication challenges institutions in their compliance with key elements of CMS Conditions of Participation and Joint Commission Standards.  The practitioner responsible for dispensing the final product to the patient guarantees that the drug’s integrity has been maintained.  By using a medication not provided by the organization, the pharmacist might not always be able to ensure appropriate pedigree, storage, procurement, distribution, and control since these products were provided by another pharmacy in or outside of the state of Illinois.

The “white/brown bag” medication does not follow the traditional supply chain.  Not only is the organization assuming the responsibility that the integrity of the drug has been maintained; they also lose the opportunity to bill for these medications.  Practice sites may also be responsible for the costs of ancillary medications and drug administration and only some of these are reimbursable.

Health-systems also need to take into consideration the rapidly growing specialty pharmaceutical market that includes high cost, complex, self-administered medications.  These medications are used to treat conditions such as HIV, Hepatitis C, pulmonary hypertension, multiple sclerosis or organ transplant, which some community or rural hospitals might not routinely stock.  These self-administered medications are not included in the white/brown bag definitions as outlined above.

ICHP strongly encourages hospitals and health-systems to develop policies and procedures around specialty pharmacy supplied medications that take into account the practice setting, balance the risk of not providing the medication to the patient in a timely manner, and take into consideration the restrictions of specialty pharmacy distribution.

Replaces Patient Supplied Medications

Revised 2015