White Bagging Can Pose Array of Logistical, Contractual and Communication Issues

As the practice of white bagging grows, Elan Rubinstein, Pharm.D., principal at EB Rubinstein Associates, tells AIS Health that the approach has many potential issues that should be addressed in payer contracts with specialty pharmacies and providers:

✦ “If a drug is administered to the patient as prescribed and as supplied under white bagging by the specialty pharmacy, how is the payer informed — via a billing that shows administration of the drug’s J-code and administered number of HCPCS [i.e., Healthcare Common Procedural Coding System] units, but with an indicator that this is for information purposes, not for reimbursement to the practice? If so, does the payer match up the specialty pharmacy billing with the provider billing to validate that the drug was administered as prescribed?”

✦ “What happens with excess drug if the dosage isn’t exactly equivalent to a round number of supplied vials? Obviously, the open vial cannot be returned to the specialty pharmacy. But may a physician in the practice administer the excess drug to another patient, and, if yes, how is that billed since 100% of that drug was already paid for?”

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