Representative NDC on Electronic Prescriptions Do Not Infer Specificity

When electronic prescriptions were first introduced, they were supposed to be more convenient for patients and cause less errors at the pharmacy (due to the legible nature of the information being sent from the prescriber). In practice, we know this has not always been the case. The directions may be confusing, the quantity not specified, and even the product selection could be left to interpretation.

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While an NDC on an electronic prescription might give you reassurance on the product prescribed, pharmacies need to exercise caution. According to the NCPDP Representative NDC Use in Electronic Prescribing Fact Sheet,

“The representative NDC used is not intended to infer specificity or preference to the embedded manufacturer/labeler. The receiving pharmacy should not assume physician intent and can utilize their own drug selection and substitution logic based on proprietary logic and compliance with any state/federal laws and regulations as needed.”

Additionally, an NDC is not required to be sent by a prescriber on an electronic prescription, only the description of the medication. PBM auditors are likely to ignore the NDC on an electronic prescription in most cases and require a pharmacy to clarify any ambiguous product descriptions. For example, a prescription for Metformin HCL ER 500 mg with no other indication of dosage form. Even if a representative NDC is present that would imply a particular dosage form, an auditor will likely expect the pharmacy to clarify if the generic for Glucophage® XR, Fortamet®, or Glumetza® was intended.

However, being hypocrites, auditors will also try to use the representative NDC against a pharmacy. For example, if a prescription indicated representative NDC 00186-0370-28 (which is for Symbicort® 160/4.5 as a 6.9 g institutional pack size), but the pharmacy dispensed Symbicort® 160/4.5 inhaler at the retail pack size of 10.2 g; PAAS has seen auditors mark these claims as discrepant for dispensing the ‘wrong product’ even though it goes against NCPDP guidance (also predicated on quantity/unit of measure being prescribed).

PAAS Tips:

  • Prescribers typically do not know what product NDC they are selecting from their drop-down boxes in their electronic software, so pharmacies should not rely on the representative NDC on the electronic prescription as prescriber intent.
  • Clarify any ambiguous product descriptions or mismatched information with the prescriber before dispensing and make a clinical note on the prescription.
  • Clinical notes should include the date, name and title of who you spoke with, summary of discussion, and your initials.

Jenevra Azzopardi, CPhT
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