March 21, 2025

Feedback Requested on PQAC 'White Bagging' and 'Brown Bagging' Rulemaking

The Pharmacy Quality Assurance Commission has begun rulemaking specific to alternative distribution models or, as they are more commonly referred to, "white bagging" and "brown bagging," of injectable medications. The draft under consideration proposes the banning of brown bagging, which would mean facilities are prohibited from receiving prescriptions that have been received, stored, and handled by the patient or patient's representative.

The draft allows for white bagging, the delivery of specialty medications to the physician for administration, when certain circumstances are met. Those circumstances include:

• When the receiving facility cannot directly procure the filled prescription through standard distribution channels such as a manufacturer, wholesaler, or outsourcing facility.
• When the receiving facility cannot compound the filled prescription at the health care facility where the filled prescription will be administered by a health care professional.

The draft rule does not apply to:

• Filled prescriptions sent by dispensing facilities to receiving facilities that are under common ownership or control of a corporate entity via an intracompany transfer.
• Filled prescriptions sent by a compounding pharmacy or registered outsourcing facility based on an order made by the receiving facility.
• Filled prescriptions for home infusion patients.

The complete rule draft is available here and we encourage your review. Should you have feedback on the rules, please email WSMA Associate Policy Director Billie Dickinson.