February 1, 2001 NUBC NDC Issues; discussion of use and value – pros/cons for NDC on institutional and professional claims
IDX develops and implements innovative information solutions that help its customers to be more successful at improving the quality of care, serving patients more efficiently, reducing costs, and more effectively analyzing their businesses. IDX products are used daily by more than 118,000 physicians. IDX products are installed at more than 2,065 customer sites nationwide, including more than 265 large group practices which average 303 doctors per group, and more than 200 IDNs of some 370 hospitals.
IDX has been investing in the HIPAA area for the past two years. It has an overarching HIPAA Team with dedicated teams for his product sets and services, and its internal structure, with dedicated domain experts from each of its five business units engaged in the HIPAA work.
IDX fully supports the general intent of the Electronic Transactions and Code Sets final rule. We believe that complexity of the new regulation in converting from HCPCS J codes to NDC for a large number of our customers may make it very difficult for them to meet the implementation date of October 16, 2002.
Almost all of IDX’s customers are impacted by this new HIPAA regulatory requirement. The survey of our customer base informs us that our physician practice customers currently are using J codes almost exclusively. The survey also informs us that we have hospital and specialty practices using our products that currently use both NCD and J codes.
IDXtendâ , IDX’s practice management product is the most heavily impacted as it only uses J codes in the current version. IDX’s LastWordâ hospital pharmacy module uses both NDC and J codes and passes either into the billing system. IDX’s radiology product allows the customer to set or enter and use either NDC or J codes to pass to a billing system.
The questions below will have a multiplicity of answers as it will depend on what the provider has used historically. There is no one-to-one match between the code sets. NDCs are more specific than J codes to a certain degree, and permit measured values for drug, form and dosage, but J codes permit entry of more than drugs and biologics. Currently, there is no cross walk or conversion table for these two sets of codes. The temporary approach available now is the ANSI X12 “fudge” of assigning a new manufacturing code to a J code to make it “look like” an NDC code.
Questions:
1. Have you or your organizational members performed a gap analysis to compare the drug and biologic data you already have available electronically with the requirements that are contained in the HIPAA transactions (rules and guides). If so what gaps are there between the data elements (and code sets) you collect electronically and what is within the HIPAA X12 837 Claim and Encounter Transactions Rule and Implementation Guide?
IDX is in the middle of the gap analysis of its product sets comparing the drug and biologic data currently collected to that mandated by HIPAA and within the implementation guide for 837 Claim and Encounter Transactions.
The HIPAA requirement to move from HCPCS J codes to NDC is a very significant impact on IDX’s software and our medical group practices customers’ processes. The IDXtend product line is directly impacted by the mandated code set change. This product line is used by approximately 100,000 of the physicians outlined above. The requirement includes mandated changes to IDX product dictionaries, screens and reports.
IDX’s other product sets are not as heavily impacted. There appear to be minimal problems for IDX’s radiology product, and for the LastWord hospital pharmacy module.
2. Is the gap a barrier for you to implement the HIPAA 837 standard? If so, what are your plans to resolve the barrier?
Yes, the change from the HCPCS J codes to the NDC for professional and institutional 837 is a significant barrier to both IDX and its customers. Substantial changes will have to be made to the products and their associated databases.
IDX will need to enhance its product set by adding new dictionary fields and screen/report fields and add field length in the data base to support the NDC codes.
Analyses of the information provided to the Department regarding the implementation of NDC codes, and a re-review of the comments received on the NPRM shows that we may have been premature in moving to NDC codes for institutional and professional providers. Further analyses will be necessary to determine if and how this standard should be changed.
As a result, we would like you to consider answering the following additional questions in your testimony, if possible:
3. What problems would arise if we revise the standard to allow J codes to be used for institutional and professional identification of drugs instead of NDC?
It is IDX’s opinion that for some people in the industry it will further confuse an already complex situation, especially if it is the Department’s future goal to move from J codes to NDC codes.
With the need for an industry approved cross walk between the two code sets, and more work at ANSI X12 for NDCs to be of value to many of the covered entities, and to support the efficiency and interoperability goals of the HIPAA Administrative Simplification the “how” in the Department comment above and the time frame should be carefully considered.
IDX supports a considered and time sensitive move from HCPCS J codes to NDC provided the additional items that can now be included in J codes will be included in another code so that our customers will be paid for the provision of these services.
IDX supports the standardization of all clinical and billing codes.
4. Are there drugs and biological codes, which are included in the transactions?
5. What are the costs of converting NDC codes versus staying with J codes?
There are significant impacts for IDX’s medical group practice customers. Our IDXtend product will need significant changes, including changes to dictionaries, screens and reports.
6. Do hospital pharmacies use NDC codes or J codes in their operations today?
IDX’s LastWord hospital pharmacy module and product permits the use of both NDC and HCPCS J codes. The pharmacy modules used NDC exclusively until the J codes became mandatory.
Respectfully Submitted,
Susan A. Miller, Esquire
Corporate Regulatory & Compliance Manager
IDX Systems Corporation
617-266-0001, X221