In the Terminology section, NDC codes are listed as being the codes that will be used in the RTPB transaction to identify a drug product. Will consumers be selecting a “representative NDC” in an RTPB request? Physicians – let alone consumers – often have problems knowing which of many NDC codes that represent a particular drug (based on different manufacturer, package size, etc.) to select. Consumers would obviously also not know which particular generic drug is stocked at the selected pharmacy. The issue of drug identification/selection warrants much more consideration and discussion.

Existing Wording:

This code system contains example NDC 11 drug product identifiers, used to identify requested and alternative medications in the real-time pharmacy benefit check process. This code system normalizes NDC codes by removing dashes and standardizing the length of each NDC segment. This is a placeholder to be replaced prior to publishing with an HL7/FHIR maintained URL (currently being established).