June 7, 2021

Caroline D. Juran, RPh
Executive Director
Virginia Board of Pharmacy
9960 Mayland Drive, Suite 300
Richmond, Virginia 23233

Re: Regulations Governing the Practice of Pharmacy (18 VAC 110-20)

Dear Ms. Juran,

On behalf of Inova Health System, I write to share our perspective on 18VAC110-20, a proposed regulation related to the practices commonly referred to as “white bagging” and “brown bagging.”  These policies under consideration are impactful to many of the most vulnerable patients in the communities we serve.

At Inova, safety is a core principle in guiding our “patient always” organizational value. “White bagging” policies raise serious patient safety and experience concerns, especially for oncology patients with complex needs.  Chemo and immunotherapies are highly complex treatments that require skilled compounding and monitoring – fragmenting the care team as a result of a mandatory white bagging policy places patient safety at risk.  

Additionally, in many cases infusion drugs are administered with a highly specific dosage that can fluctuate based on a patient's clinical status on a given day. On-site pharmacists and the patient care team will collaborate in real time to adjust drug dosage based on the infusion day’s bloodwork and the specific needs of the patient regarding their care plan. Mandatory use of white bagged drugs can delay treatment while waiting for a new drug order or shipment and delivery from an external pharmacy, leading to suboptimal patient outcomes and experience. Moreover, there is an additional risk of cost increases given the greater number of missed doses, interruptions to critical treatment, wasted drugs, and higher out of pocket patient cost due to multiple unnecessary drug copays.

Doctors, oncology nurses, oncology infusion trained pharmacists, hospitals and health systems are best equipped to manage the complex needs of our patients in a cost-effective manner that is safe, highly reliable, and most importantly, centered around the patient.  The recommendations submitted by the Virginia Hospital and Healthcare Association in their comment letter dated May 21, 2021 are consistent with those priorities, and Inova concurs with the recommendations and comments shared in that letter.

Thank you for your consideration of our perspective on this issue of importance to Virginians and their healthcare needs.

Sincerely,

Melanie Massiah-White, BS Pharm, MHA
Vice President & Chief Pharmacy Officer
Inova Health System