Submitted by knicholson@nacds.org on 2022-04-18
NACDS Comments on USCDI Draft v3
The National Association of Chain Drug Stores (NACDS) strongly encourages ONC to include the National Drug Code (NDC) in addition to RxNorm as a Vocabulary Standard for the Data Class of Medication. The NDC Code is a HIPAA-named code set and is pervasive in describing specific medications in the ambulatory care setting. The majority
of NCPDP standards include the NDC as the primary drug identifier. The NCPDP Telecommunication Standard is used to process over 4.5 billion claims transactions per year, the vast majority of whichrequire only the NDC to be used in identifying the dispensed medication. 1.91 billion prescriptions are sent electronically from prescribers to pharmacies using the NCPDP SCRIPT Standard, where NDCs are almost exclusively used to represent the medication prescribed. Additionally, the industry uses the NDC in other important electronic prescribing transactions to accurately report the specific product in patient medication history, prescription renewals, prescription transfers, prior authorizations, medication changes, product recalls, adverse event reporting, REMS reporting and Real Time Prescription Benefit. RxNorm does not identify the specific packaged product dispensed and would not be as useful in most of these transactions.
Submitted by nradov on 2022-09-23
UHG comment on adding NDC
UnitedHealth Group requests that ONC add the FDA’s National Drug Code (NDC) Directory as an Optional item in the Allergies and Intolerances class Substance (Medication) data element list of Applicable Vocabulary Standards. This would improve consistency with the Medications class Medications data element which already includes NDC in the list of Applicable Vocabulary Standards as of USCDI V3. Many electronic health record (EHR) and pharmacy applications store both medications and drug intolerances using NDC codes rather than RxNorm, and are unable to automatically convert patient data from NDC to RxNorm when sending data to external applications. While RxNorm is preferred for most use cases, for interoperability purposes it is always better to exchange coded data rather than unstructured text. Adding NDC as an option will enhance meaningful interoperability and improve patient safety by allowing automatic detection of potential adverse drug reactions during electronic prescription (eRx) workflows.