June 8, 2021

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

Subject: 18 VAC 110-20 Proposed Regulations Governing the Practice of Pharmacy

Dear Ms. Juran,

Carilion Clinic is a not–for–profit, integrated health care organization based in Roanoke providing high quality care for nearly one million Virginians. Our mission, To Improve the Health of the Communities We Serve, is conducted through our comprehensive network of hospitals, primary and specialty physician practices and other complementary services. Our western Virginia service area spans much of the I-81 corridor, and much of it is rural.

Thank you for the opportunity to provide comments relating to the proposed regulations governing the practices often referred to as “white bagging” and “brown bagging” (18VAC110-20). The proposed policies being considered have the potential to adversely impact some of the sickest and most vulnerable of our patients. As you consider these and other stakeholder comments, it is our belief that patient safety must be at the core of these considerations.

I am aware that the Virginia Hospital and Healthcare Association (VHHA), has already provided significant, detailed comments on behalf of member health systems relating to the proposed regulatory changes in their letter of May 21, 2021. VHHA touched on many of the same thoughts we have, and we are aligned with those comments and recommendations, so I will not repeat them.

As a pharmacist, I am acutely aware of the complex medical conditions that many of our patients experience, especially those under oncology care. Their safety is our highest priority, as it is for all patients. Complex chemo and immunotherapies demand highly skilled and strictly- controlled compounding, handling, storage, monitoring and timing. “White bagging” policies pose significantly higher risks for these patients, adding additional parties and steps to the treatment processes they will experience. As a colleague shared, “fragmenting care adds another risk element to the care equation and threatens patient care”.

Our providers must address changing patient needs on a daily and often, hourly basis. This is particularly true at our infusion centers. Being able to address these changes immediately in our clinical settings with our patients is an imperative. Requiring mandatory use of “white bagging” for a drug from an external supplier can complicate patient care, cause unnecessary and harmful treatment delays, adversely impact patient outcomes, increase waste, and yield higher costs. None of these are beneficial to our patients.

In short, the patient care teams in our health system are in the best position to address the pharmacy and other complex needs of our patients and deliver high quality, cost-effective care when and where it is needed. 

Our industry is a complex, but unique and critically important one. We have the privilege of seeing and treating patients in some of their happiest moments, as well as during some of their most difficult ones. This privilege and responsibility demands the most competent, capable and compassionate skills of our providers and patient care teams. it also demands that we have the resources available to support these patients when needed. 

On behalf of Carilion Clinic, and the patients and communities we have the honor of serving, thank you for the opportunity to comment on the proposed regulations and to write in support of the recommendations offered by VHHA. We appreciate your thoughtful consideration.

Sincerely,

Chad E. Alvarez PharmD, MBA                                                                                          Senior Director of Pharmacy                                                                                              Carilion Clinic