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8 Digit NDC Issue #94
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It seems that NDCs should always be normalized to the full 11 digits. The first 9 digits could then always be used for reporting without ambiguity. |
The rule indicates 10/11 byte NDC is required. "The NDC, in contrast, is a unique 10-digit or 11-digit |
Note on NDC from here, on page 65:
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Is the consensus that we should follow the rule, which specifies 10 or 11 digit NDCs be used, and not the schema which calls for 8 digits and will cause confusion? Can someone from HHS please weigh in and provide clarification? |
If we do the reporting at the NDC 8 or 9 level, can CMS please establish standardized business rules to compute pricing if the pricing varies at the NDC 9 level? |
The prescription drug schema indicates that NDC reporting for prescription drugs should be done at the 8 digit level as the last two digits of an NDC are for package size/quantity. In looking into this further, for example, NDC 000740124 for Humira. The first 8 digits of the NDC are the same for Humira Pen Peds, Humira Pen Kit, Humira Pen 80/0.8ml, Humira Pen Kit CD/UC/HS. While each product has the same first 8 digits, the prices differ between the products. How do we determine which drug to select when each NDC is slightly different in price at the 10 digit level?
Another example is Cosentyx. The NDC 000780639 is used for both the 300 dose pen, 150 mg/ml pen, the 150 mg/ml pen, and the 300 dose. The price differs significantly depending on which full 10 digit NDC is used.
How do we convert an 10 or 11 digit NDC to 8 digits? When an NDC is in the 5-4-2 format (ID Format Code 6 on the Medispan File), we would be dropping the last digit of the product code. Moreover, how do we convert an 11 digit NDC to 8 digits where the ID Type Code is 1 and the ID Format Code is 1, 2, 3, or 6?
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