There is no doubt that white bagging and payer mandates that hospitals can only source drugs from a narrow selection of payer-affiliated specialty pharmacies was one of the most notable afflictions facing health system pharmacy leaders in 2021. White bagging practices have accelerated over the past few years, and pharmacy leaders and professional organizations are banding together at the state and national levels to shine a spotlight on the many negative implications that white bagging has on patient care and safety, total cost of care and overall hospital financial performance. Thus far eleven states have introduced bills on white bagging, and three states have even passed laws.
Despite the positive momentum in addressing these concerns, one can’t ignore the immediate and massive savings these practices bring to employers and health plans, thus efforts to expand white bagging and site of care restriction practices will likely continue to spread in 2022 as payers are quickly searching for ways to control rapidly rising specialty drug expense. Pharmacy leaders must respond quickly and aggressively, or risk continued erosion of patients and dollars out of their health systems!
In addition to white bagging, alternative site of care strategies will increasingly be pursued by payers to reduce payments. Such site of care optimization policies will encourage patients to move away from higher-cost settings (such as hospital infusion centers) towards lower-cost settings such as physician’s offices, ambulatory infusion centers/suites, and the patient’s home to receive specialty infusion medication. When clinically appropriate, receiving these infusions in the home setting not only lowers the cost of care, it also provides additional benefits such as improved patient satisfaction and convenience, fewer disruptions to patient work schedules, decreased risk of exposure to nosocomial infections, and faster patient hospital discharge.
What can health system pharmacy leaders do?
Payer mandates and benefit designs that financially incentivize the patient to receive high-cost infusion medications outside of the hospital in lower cost and more convenient settings are likely here to stay. Most payers have already implemented or are in the process of implementing various approaches to direct high-cost infusion care outside of the hospital outpatient setting. There are, however, great strategies health systems can employ to ensure a reasonable cost to the payer while maintaining patient access and positive margins within the health system. Visante recommends that pharmacy leaders take the following actions to maximize patient care, safety and convenience:
- Move swiftly to create an internal home infusion therapy program with freestanding infusion suites within the organization’s pharmacy enterprise. This will provide two new sites of care within the system, enabling the organization to more effectively negotiate with payers to keep high-quality affordable care within the system.
- Collaborate with senior leadership and Managed Care Contracting. Pharmacy leaders must partner with Managed Care Contracting teams to negotiate payer contracts that are inclusive of all internal sites of care. Pharmacists can help make their colleagues aware of the safety risks as well as the impact that white bagging practices have on the bottom line of the organization. Advocate that current care models be reassessed. Seek support to consider innovative shifts in care delivery, such as home infusion as described above and billing under the pharmacy benefit as described below.
- Negotiate for the hospital’s specialty pharmacy to become in-network with payers for patients served by the health system to ensure optimal continuity of care. Hospitals need to be able and willing to process high-cost infusion drug claims through a PBM and bill the medical payer for the service under the pharmacy benefit.
- Take a bold stance on white bagging in your organization. Pass a firm hospital policy prohibiting this practice and collaborate with managed care contracting, medical staff and others to ensure this policy is complied with in all sites of care.
- Get engaged. Support local and national efforts to address the practice of white bagging.
Developing and implementing a home infusion strategy for your health system is similar to the level of importance that starting a specialty pharmacy program was ten years ago. Payers are starting to mandate home infusion as a preferred site of care for specialty infusions and requiring that these services be paid separately from the traditional hospital contract. Pharmacy leaders who are proactive in establishing a comprehensive internal home infusion therapy program will be well-positioned for success in tomorrow’s marketplace, as this strategy improves patient care and convenience, and presents a new source of revenue for the organization.
Visante consultants have deep contemporary expertise in site of care mitigation and all aspects of internal specialty pharmacy and home infusion therapy program business planning and implementation.