Section 7.2: Buy-and-Bill, White Bagging, & Brown Bagging Models
Mastering the different specialty drug procurement and delivery models. Understand the financial risks and operational workflows of provider-administered (“buy-and-bill”) vs. pharmacy-dispensed (“white/brown bagging”) therapies.
Buy-and-Bill, White Bagging, & Brown Bagging Models
From Financial Guardian to Air-Traffic Controller: The Pharmacist’s Role in the Specialty Drug Supply Chain.
7.2.1 The “Why”: The Drug, The Money, and The Model
In the previous section, we decoded the complex language of billing. We learned *how* to file a claim. In this section, we answer a more fundamental question: “Who paid for that drug in the first place?”
In your community pharmacy world, the answer was simple. Your pharmacy bought the drug, you dispensed it, and the payer (or patient) paid you for it. The patient left with the drug. This single, linear model is a luxury you will no longer have. In the world of provider-administered specialty drugs, the *logistical model*—the channel through which the drug is purchased, stored, and delivered to the patient—is a critical, strategic decision with massive financial and clinical consequences.
The three core models we will dissect—Buy-and-Bill, White Bagging, and Brown Bagging—are not just operational workflows. They are competing business philosophies that shift financial risk, regulatory burden, and operational control between three key players: the Payer, the Provider, and the Patient. As a specialty pharmacist, you are the lynchpin. Your EMR, your inventory, your purchasing accounts, and your clinical expertise are the central hub through which all three models must be managed, often simultaneously, for different patients, with different payers, all in the same clinic.
Why is this your “masterclass” to own?
- When a clinic loses $15,000 because a “Buy-and-Bill” drug was denied after administration, they will turn to you, the Financial Guardian, to build a process that prevents it from happening again.
- When an infusion is canceled because a “White Bagged” drug from an external specialty pharmacy didn’t arrive on time, the provider will turn to you, the Air-Traffic Controller, to build a tracking system.
- When a patient arrives with a “Brown Bagged” drug that’s warm to the touch, the nurse will turn to you, the Gatekeeper of Quality, to make the safety call.
Your ability to design, implement, and manage these disparate channels is not a “billing” function; it is a core executive-level pharmacy competency. This section will give you the playbook for all three.
Pharmacist Analogy: The Restaurant & The Bottle of Wine
Imagine your infusion center is a high-end restaurant. The patient is the customer. The infusion (the CPT admin code) is the “service” or “corkage fee.” The expensive biologic (the J-code) is a $5,000 bottle of rare wine. Here is how the three models play out.
1. The “Buy-and-Bill” Model (The House Wine)
The restaurant (your clinic) buys the $5,000 bottle of wine from its distributor and puts it in its own cellar (your pharmacy inventory). The restaurant is “buying” the wine and takes on all the risk. If the bottle breaks or spoils, the restaurant eats the $5,000 cost. When the customer orders the wine, the restaurant serves it and then “bills” the customer (the payer) for the wine (e.g., $6,000) *plus* the service.
Risk vs. Reward: Highest financial risk, but also the highest potential reward (the $1,000 “profit margin” on the wine). You are a retailer of wine.
2. The “White Bagging” Model (The Mandated Delivery)
The customer’s “Wine Club” (the payer’s specialty pharmacy) ships the $5,000 bottle directly to the restaurant, with the customer’s name on it. The restaurant (your clinic) never buys the wine. It simply accepts the delivery, holds it for the customer, and serves it to them when they arrive. The restaurant can only bill the customer for the “corkage fee” (the CPT admin code).
Risk vs. Reward: Zero financial risk on the wine, but also zero reward. You are now just a “bring your own bottle” (BYOB) establishment, but you don’t even get to choose the bottle. You are a service provider, not a retailer.
3. The “Brown Bagging” Model (The Patient Carry-In)
The customer buys the $5,000 bottle of wine from a local shop, puts it in the trunk of their hot car, and brings it into the restaurant themselves. The restaurant has no idea how that wine was stored or handled. It could be spoiled, fake, or the wrong bottle entirely. The restaurant is terrified to serve it due to the liability risk.
Risk vs. Reward: Zero financial risk, but maximum safety and liability risk. Most high-end restaurants would refuse, just as most hospitals forbid this model.
7.2.2 Deep Dive: The “Buy-and-Bill” Model (The House Wine)
Buy-and-Bill is the traditional model for provider-administered drugs under the medical benefit. As the name explicitly states, the provider (the hospital, the clinic) BUYS the drug, manages it in their own inventory, administers it to the patient, and then BILLS the payer for both the drug (HCPCS J-code) and the administration (CPT code).
This model effectively turns the provider into a specialty pharmacy and a bank. They are purchasing and dispensing a drug, and they are floating the high cost of that drug for the 30, 60, or 90+ days it takes for the payer to provide reimbursement. Your role as the pharmacist is to be the primary manager of this entire high-stakes process.
7.2.2.1 The Buy-and-Bill Workflow: A Visual Guide
Understanding the flow of money and medication is essential. This is your mental map.
7.2.2.2 Financial Implications: The High-Stakes Game
This model is a high-risk, high-reward proposition. The provider is essentially a small business reselling high-cost goods. As the pharmacist, you are the chief operating officer of this business.
| Stakeholder | Pros (Advantages) | Cons (Risks & Disadvantages) |
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| Provider (Clinic / Hospital) |
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Pharmacist’s Buy-and-Bill Clinical & Financial Risk Mitigation Playbook
Your primary job in this model is to build a “firewall” to prevent financial loss. This is your playbook.
- Rule 1: No PA, No Order. You will build a “hard stop” in your workflow. The pharmacy will not purchase any drug until a valid, approved Prior Authorization is on file and attached to the patient’s chart. This is your single most important defense.
- Rule 2: Verify the Benefit, Not Just the PA. A PA is not a guarantee of payment. Your team must do a full Benefit Investigation (BI). Is the PA for the medical benefit or pharmacy benefit? Does the patient have a $10,000 deductible they haven’t met? You must know this *before* you order.
- Rule 3: Implement JIT Inventory. You will not order drugs “for stock.” You will order drug A *for patient A* to arrive 1-2 days before their scheduled infusion. This minimizes on-hand inventory, reduces spoilage risk, and ties a drug purchase directly to a scheduled, authorized service.
- Rule 4: The Pre-Administration “Final Check.” You will create a pre-infusion checklist. Nurse/MA confirms patient has arrived. You or your tech pull the chart.
- – Does the patient still have active coverage? (Run a new eligibility check).
- – Is the PA still valid? (Check the dates).
- – Does the provider’s final order match the PA? (PA for 350 mg, order for 400 mg? STOP. This is a denial risk).
- Rule 5: Flawless Charge Capture. You will design the EMR documentation (the “MAR”) to capture every billable item.
- – Field for NDC (scanned from vial).
- – Field for Dose Administered (e.g., 350 mg).
- – Field for Dose Wasted (e.g., 50 mg).
- – Field for Infusion Start/Stop Time (to bill for `96415` add-on hours).
7.2.3 Deep Dive: The “White Bagging” Model (The Mandated Delivery)
White Bagging is a model driven entirely by payers seeking to control costs. Payers (especially those with their *own* in-house specialty pharmacies) will mandate that a drug cannot be provided via Buy-and-Bill. Instead, the provider must send the prescription to the payer’s designated external Specialty Pharmacy (SP). That SP will adjudicate the claim (on the pharmacy benefit), collect the patient’s copay, and then ship the patient-specific prescription to the provider’s office for administration.
This model financially eviscerates the provider’s infusion center, turning it from a revenue center into a “cost center” that only gets paid for the (much lower) administration fee. Operationally, it creates a logistical nightmare that you, the pharmacist, are now responsible for managing.
7.2.3.1 The White Bagging Workflow: A Visual Guide
Note the critical differences from the Buy-and-Bill workflow. The money and the drug flow in completely different paths.
7.2.3.2 Financial & Operational Implications
This model shifts all financial risk *off* the provider, but in doing so, it also removes all revenue and creates a logistical nightmare. Your role pivots from “Financial Guardian” to “Air-Traffic Controller.”
| Stakeholder | Pros (Advantages) | Cons (Risks & Disadvantages) |
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| Provider (Clinic / Hospital) |
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| Payer |
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Pharmacist’s White Bagging Operations & Safety Playbook
Your primary job is to build a safe and reliable workflow to manage the chaos. This is non-negotiable.
- Create a “White Bag” Quarantine Zone: You must have a physically separate, clearly-labeled shelf or refrigerator. This area is for “Patient-Owned Medications” ONLY. It must not be possible to co-mingle these with your Buy-and-Bill inventory.
- Implement a 100% Verification Policy: All white-bagged drugs must be delivered to the pharmacy, not the infusion suite. Your team (pharmacist or tech) must open every single package and perform a formal check.
- – Is the cold chain monitor (if present) good?
- – Does the Rx label match the patient in your EMR?
- – Is it the correct drug, dose, and diluent?
- – Are the vials intact? Is the expiration date acceptable?
- Create a “Check-In” Log: You must have a log (electronic or paper) to “check in” the drug. “Received 10/24/25 @ 10:30 AM via FedEx. Verified by RPh Smith. Stored in White Bag Fridge.” This creates your chain-of-custody documentation.
- Proactive Scheduling Communication: Your infusion schedulers must be trained to call the patient 48-72 hours *before* their appointment.
The Script: “Hi Mrs. Jones, I’m calling to confirm your Remicade infusion on Wednesday at 2 PM. Your insurance requires your drug to be shipped from ABC Specialty Pharmacy. Can you please confirm that you have spoken to them and that your drug is scheduled to be delivered to our office by Wednesday?”
If the answer is “no,” the appointment is rescheduled *before* the patient shows up. - Waste & Dosing Change Policy: Your clinic must have a clear policy for when the delivered dose does not match the provider’s order.
- – The Problem: SP sends 350 mg. Provider wants 400 mg.
- – The (Bad) Solution: “Borrowing” 50 mg from your Buy-and-Bill stock. This is an accounting nightmare. How do you bill for that 50 mg? You can’t.
- – The (Correct) Solution: The infusion must be rescheduled. The provider must send a new Rx to the SP for 400 mg. This is a terrible patient experience, but it is the only way to manage the model safely.
7.2.4 Deep Dive: The “Brown Bagging” Model (The Patient Carry-In)
Brown Bagging is the most operationally simple and clinically terrifying of all models. In this scenario, the patient is responsible for all aspects of their specialty drug. The patient picks up their high-cost, temperature-sensitive biologic from the specialty pharmacy (or any pharmacy) and is responsible for storing it at home and then transporting it themselves to the provider’s office for administration.
This model transfers 100% of the drug cost and inventory risk to the patient. It also transfers 100% of the chain-of-custody liability to the provider. For this reason, most hospitals and reputable infusion centers have a strict policy forbidding brown bagging. As a pharmacist, you will be the author and chief defender of this policy.
7.2.4.1 The Brown Bagging Workflow: A Visual Guide
This workflow is simple and fraught with peril at every step.
7.2.4.2 Financial & Liability Implications
This model is a non-starter for most health systems. The risk almost always outweighs the (non-existent) benefits.
| Stakeholder | Pros (Advantages) | Cons (Risks & Disadvantages) |
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| Provider (Clinic / Hospital) |
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Pharmacist’s Playbook: The “No Brown Bagging” Policy
This is a policy you must champion. Your job is to educate administration, providers, and schedulers on *why* this is so dangerous. Your policy should state:
“To ensure patient safety and maintain regulatory compliance with drug chain of custody, [Our Hospital/Clinic] does not permit the administration of patient-supplied (‘brown-bagged’) medications. All medications for administration must be procured by the clinic (‘Buy-and-Bill’) or shipped directly from a Payer-approved specialty pharmacy to our facility (‘White Bagging’), where they can be inspected and stored by the pharmacy department.”
When you get pushback (“The patient insists!”):
The Script: “Doctor, I cannot in good faith verify the safety or efficacy of that drug. We have no record of its storage or handling since it left the pharmacy. If we administer it and the patient has a bad outcome or the drug doesn’t work, our institution is liable. My license is on the line, and so is yours. We must adhere to our policy and reschedule the patient using one of our approved channels.”
7.2.5 Comparative Masterclass: All Models at a Glance
This is your ultimate cheat sheet. This table summarizes the entire section and is your primary tool for educating providers, administrators, and billing staff on the complex ecosystem you are managing.
| Metric | Buy-and-Bill (“House Wine”) | White Bagging (“Delivered Wine”) | Brown Bagging (“Carry-In Wine”) |
|---|---|---|---|
| Who Buys the Drug? | Provider / Clinic | External Specialty Pharmacy (SP) | Patient |
| Who Bears Financial Risk? | Provider / Clinic (Inventory Cost + Denial Risk) | Payer / SP (Inventory) | Patient (Cost of Spoilage/Loss) |
| Who Bears Liability Risk? | Provider (Standard Malpractice) | SP (Dispensing) + Provider (Admin) | Provider (Extreme Liability) |
| What Does Clinic Bill For? | J-Code (Drug) + CPT (Admin) | CPT (Admin) ONLY | CPT (Admin) ONLY |
| Clinic Revenue Model? | Revenue Center (Drug Margin + Admin Fee) | Cost Center (Admin Fee Only) | Cost Center (Admin Fee Only) |
| Benefit Billed for Drug? | Medical Benefit | Pharmacy Benefit | Pharmacy Benefit |
| Patient Cost-Share? | Deductible + Coinsurance (e.g., 20%) | Flat Copay (e.g., $50) | Flat Copay (e.g., $50) |
| Chain of Custody? | Secure. (Distributor -> Pharmacy -> Patient) | Secure. (SP -> Pharmacy -> Patient) | BROKEN. (SP -> Patient -> ??? -> Clinic) |
| Pharmacist’s Core Role | Financial Guardian & Inventory Manager | Air-Traffic Controller & Safety Verifier | Gatekeeper & Policy Enforcer |
7.2.6 The Emerging Models: “Clear Bagging” and Other Hybrids
The battle between Buy-and-Bill (provider control) and White Bagging (payer control) has led to the creation of hybrid models as organizations try to reclaim safety and control.
7.2.6.1 Clear Bagging (The “In-House” White Bag)
“Clear Bagging” is a response from large, integrated health systems (IDNs) that have their own specialty pharmacy. It’s a way to “white bag” to themselves. In this model, the provider and the specialty pharmacy are part of the same parent company.
- Workflow: 1. Patient is diagnosed in the clinic. 2. Provider sends the Rx to the in-house specialty pharmacy. 3. The in-house SP adjudicates the claim (pharmacy benefit) and prepares the *patient-specific* drug. 4. The in-house SP pharmacy tech delivers the labeled, patient-specific drug to the *in-house infusion center*. 5. The infusion center administers the drug and bills for the CPT admin code only.
- Why do this? The Health System as a whole gets to capture the pharmacy margin (at the SP level) *and* the administration fee (at the clinic level). It keeps all the revenue “in-house.” It also restores 100% of the safety and chain-of-custody control, as *your* pharmacy colleagues are the ones dispensing the drug.
- Your Role: As a pharmacist, you may be on either side of this. You might be the SP pharmacist dispensing the drug, or the infusion pharmacist receiving it. Your job is to build the seamless EMR and delivery handoff between the two departments.
7.2.6.2 White Bagging to Pharmacy
This is a subtle but important variant of white bagging. Instead of having the external SP ship the drug to the *infusion suite*, the provider mandates that all white-bagged drugs must be shipped to the in-house pharmacy. This is the model you should champion if your organization is forced to accept white bagging.
- Why do this? It routes all medications through the “front door” of the pharmacy. It prevents coolers from being left unattended at a nurse’s station. It allows *you* and your trained team to perform the critical “Check-In & Verification” step (from 7.2.3.2) in a controlled environment.
- Your Role: You are the central receiving hub. You receive, inspect, log, and quarantine the white-bagged drugs. You then deliver the *verified* drug to the infusion suite at the time of the appointment, just as you would with a Buy-and-Bill drug. This model restores safety and sanity to the white bagging process.
7.2.7 Your New Identity: The Logistics & Channel Master
As we conclude this section, your perspective on “dispensing” should be fundamentally altered. In your community practice, dispensing was a single, linear act. In the specialty world, the “channel”—the path the drug and the money take—is a complex, strategic choice.
You are no longer just a “pharmacist.” You are the master of these channels. You are the executive who can analyze the financial risk of Buy-and-Bill, build a high-reliability workflow for White Bagging, and write the patient-safety policy that forbids Brown Bagging. You are the only person in the health system who stands at the intersection of:
- Finance (Managing a multi-million dollar inventory and protecting revenue)
- Logistics (Tracking hundreds of high-stakes, time-sensitive deliveries)
- Safety & Compliance (Ensuring chain of custody and drug integrity)