Filling Prescriptions with Two NDCs – What You Need to Consider

We’ve all been in the sticky situation of having a few straggling pills left associated with one NDC that would be ideal to get off the shelf and free up some space. Maybe this NDC used to be the preferred product and now it has changed, or the manufacturer was bought out by another company. What is the proper way to bill and dispense two different NDCs on the same fill? It’s important to take both physical dispensing and claim processing into consideration to avoid the additional risk of this situation.

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It should be clear to the patient that they are receiving two NDCs when dispensing. Some pharmacies prefer to place both products in the same vial (separated with clean cotton) and include an auxiliary sticker that notifies the patient that ‘This is the same medication you have been getting. Color, size, or shape may appear different’. Note that dispensing two products in one vial could lead to misbranding the product dispensed, as there is likely only going to be only one NDC with the manufacturer and item description listed on the label. To avoid unintended allergic responses, do not use recycled cotton from manufacturer stock bottles (e.g., sulfasalazine, penicillin, etc.). Pharmacies may want to consider using two separate vials, each labeled with the correct NDC, manufacturer, and item description accurately reflecting its contents. While this method does not require cotton, it should still include an auxiliary sticker to inform the patient.

Processing the claim appropriately can be a complex endeavor. The data logged in the pharmacy dispensing software and submitted to the third-party payors has important downstream purposes. Incorrect data reflecting the claim can cause problems with FDA recalls and PBM audits.

Let’s consider an example where the pharmacy is dispensing #30 atorvastatin 20 mg tablets and only has #20 tablets of old manufacturer NDC ‘A’ and needs #10 tablets of new manufacturer NDC ‘B’ to complete the fill. Many pharmacies would process a single claim transaction with only one of the NDCs being filled. In this example, NDC ‘A’ would likely be billed as this NDC represents most of the fill. This can cause many problems including the following:

  • If there is ever an FDA recall on NDC ‘B’ that requires a claim utilization report for the pharmacy to find impacted patients, you may not be able to find this claim. Recalls may be rare, but patient safety can be at risk
  • The claim may be considered in violation of PBM contracts – identification and enforcement by PBMs may be difficult
  • The pharmacy may have an inventory shortage on a future PBM invoice audit

The best practice to avoid these issues would be to process two separate claim transactions. This way each NDC is appropriately accounted for in your pharmacy software and adjudicated to the PBM. This may require the utilization of the Submission Clarification Code (SCC) value of 62. In Section 3.1.12 Submission Clarification Code (SCC) of the NCPDP Telecommunication FAQ document defines this value as being,

“Shortened Days Supply of Same Drug, Strength and Dosage Form with Multiple NDCs Dispensed.

Used to request an override to plan limitations and/or copay benefits when there are multiple claim billing transactions for same drug and strength due to NDC change(s)”

This will tie the claims together to help align with the plan benefit parameters. When using this override on a plan that recognizes the code, the pharmacy should receive Approved Message Code (548-6F) value 023, “Prorated copayment applied based on days supply. Plan has prorated the copayment based on days supply,” according to the NCPDP Telecommunication FAQ document linked above.

PAAS Tips:

  • Pharmacies may need to contact PBM helpdesks if they do not recognize SCC-62 to resolve an early refill and/or duplicate copays
  • Pharmacies will need to assess their own risk tolerance and practicality of using SCC-62
    • While great in theory, the application may be cumbersome in workflow and not work well in your setting
    • Consider the frequency of manufacturer changes and costs for determining your own policies
  • Prescriptions for multiple package sizes require additional considerations

Lindsay Doebert, CPhT