Proposal 587: NDC Should Repeat
Proposal 587: NDC Should Repeat
Proposal adopted on FM TC 2/16/08 call:
Proposal 587: NDC Should Repeat
Short Description: Charge transactions need to accommodate multiple NDC codes, quantities and units of measure for each financial transaction (FT1). Justification: Currently there can be multiple NDC codes for each charge, that is, for each HCPCS drug code, because the manufacturers use different packaging sizes and units of measure.
The U.S. Deficit Reduction Act requires drug rebates, which in turn requires the actual dispensed amount to be included in the charge from the clinical system (e.g., pharmacy) to the billing system. An improper NDC on the bill would constitute fraud.
Example 1: The charge would be for 1 unit of HCPCS Code J9265 Paclitaxel injection that has a HCPCS dosage of 30 mg. This drug is a multi-source drug; it is made by many manufacturers. In order to administer this drug a provider may use vials from different manufacturers. Conceptually speaking a physician may use six 5 mg vials. Each from a different manufacturer. Each with its own unique NDC number. So, we have many NDCs for one unit of J9265, or more accurately six 5 mg vials each from a different manufacturer, that make up 1 unit, or 30 mg, of HCPC J9265. Or different sized vials may be used, e.g., one 20 mg vial from BEDFORD LABORATORIES (NDC code of 55390-0114-20) and one 20 mg vial from AMERINET CHOICE (NDC code of 55390-0314-20). One might treat that as one charge with two NDC’s, using the NDC codes for each product.
A list of multiple source drugs can be found at: http://www.cms.hhs.gov/DeficitReductionAct/Downloads/Top20PhysicianAdministered.pdf.
Example 2: Patient is treated at the hospital with a lotion that is administered 2 or three times daily. There is a charge for each administration of the lotion. The lotion was created compounded in the hospital pharmacy using four special ingredients for that patient. The same may be true of an IV or an oral mixture. One might treat that as one charge with four NDC’s, using the NDC codes for each ingredient.
We’ve heard that there is an X12 initiative to require be a HCPCS code for every NDC code. That does not satisfay the requirement for two reasons:
[a] until such time as a 1:1 relationship between HCPCS and NDC codes is mandated by the federal government and implemented by all our customers, we need to record multiple NDC codes per charge, and [b] HL7 is an internalational standard and should be based upon possible situations regardless of realm-specific mandates. In fact, the situation does occur outside the U.S., if relabellers are used.
Proposed Solution
Both of the following fields would be made repeating:
6.5.1.29 FT1-29 NDC Code (CWE) 01845
<add this to existing description :> There can be multiple NDC codes per charge, e.g., per HCPCS code. It is recommended to use multiple OBX segments for NDC codes following the FT1 segment for a charge, i.e., one OBX segment for each NDC code (OBX -3), quantity (OBX-5) and unit of measure (OBX-6).
6.5.1.43 [newly proposed] FT1-43 (CQ) - NDC Qty and UOM.
Version 3 Implications
In the V3 FIAB charge post transaction, the CMETs for A_Billable_Clinical_Services choices already provide the repeatability of NDC codes for one charge.
Discussion
There was some concern that different systems doing business in different ways may be incompatible…
System A: Clinical/Rx <charge: HCPCS, NDC > billing system <claim: HCPCS, NDC > payer System A needs to end multiple NDCs per charge.
System B: Clinical/Rx <charge: NDC > billing system <claim: HCPCS, NDC > payer System B does not support multiple NDCs per charge and doesn’t want multiple NDCs to be supported. If the billing system, which is not supporting multiple NDCs, ignores multiple NDCs, then important data may be lost.
One version of this proposal suggested putting the repeating NDCs in OBX segments. But in light of the different business rules discussion, FT1-29 should not be made “for backwards compatibility only”. Given this, it was pointed out that we shouldn’t have NDC codes in both FT1 and OBX. So the final adopted proposal is to make two fields in FT1 repeat: FT1-29 and FT1-43.
The proposal was adopted: 1 opposed, 3 in favor, 1 abstain.
