NDC Reporting Requirement

ASHP is working diligently to ensure that outpatient pharmacy departments are exempted from a requirement that hospital outpatient departments to report National Drug Code (NDC) numbers on single-source drugs and 20 multiple-source drugs identified by the Secretary for Health and Human Services (HHS) when submitting Medicaid claims.

State Requirements

CMS Resources

Chronology of ASHP's Activities

2008
June	ASHP Asks State Affiliates to Pursue Delay of Troublesome NDC Requirement
January	ASHP member Randy Kuiper meets with staff of Senate Finance Committee to give practitioner point-of-view on the difficulties in implementing requirement. To date, CMS has approved implementation delays for 15 state Medicaid agencies. Eight other requests are pending.
2007
February	Conducts member survey to assess potential implementation hurdles Responds to CMS proposed rule using survey results to demonstrate burden to pharmacy departments.
June	Sends joint letter with Safety Net Hospitals for Pharmaceutical Access (SNHPA) and National Association of Public Hospitals (NAPH) to leadership of Senate Finance Committee leadership asking for clarification of congressional intent to exempt outpatient pharmacy departments.
July	CMS publishes final rule; gives opportunity for additional comments.
August	Submits additional comments that emphasize the burden caused by implementation of requirement
October	Sends joint letter with SNHPA, NAPH, the Federation of American Hospitals, the American Hospital Association, the National Rural Health Association, and the National Association of Children's Hospitals to Secretary Leavitt citing patient safety concerns.
November	Sends letter with SNHPA to leadership of House Energy and Commerce and Senate Finance committees seeking clarification that hospital outpatient departments are exempt from NDC reporting. Urges state affiliate leaders to request implementation delays from State Medicaid offices.
2006
September	ASHP sends letter to Michael Leavitt, Secretary, Department of Health and Human Services, expressing concern over reporting burden. Members discuss reporting burden during visits to congressional offices during Legislative Day
November	ASHP member Agatha Nolan meets with Dennis Smith, Centers of Medicaid & Medicare Services (CMS), Director of Medicaid & State Operations to discuss impracticalities and burden of implementing reporting requirement.
December	CMS publishes proposed rule.