I have submitted the following comment:
TO: Department of Health and Human Services
Office of the Secretary
45 CFR Part 162
CMS-0003-P (NDC NPRM)
CMS-0005-P (Addenda NPRM)
FR: Laurie Valentine
Venturi Technology Partners
2377 Gold Meadow Way, Suite 280
Gold River, CA 95670
DT: June 21, 2002
RE: Public Comments on the Notice of Proposed Rule Making (NPRM)
Modifications to Standards for Electronic Transactions and Code Sets
Description:
Public comment regarding the 004010X098A1 837P Implementation Guide
(IG) that is named as the standard in the Addenda NPRM CMS-0005
The IG Addenda CMS-0005 conflicts with the repeal of NDC codes
NPRM CMS-0003
1. Page 54 837P 004010X098A1 Addenda (original page 401)
New Note Added N4 (NDC codes) only used if J Codes are not allowed for
use under HIPAA (also on addenda page 77)
If J codes are allowed under HIPAA, as proposed in NDC NPRM, then you
can not use the NDC identifier.
2. The NDC NPRM CMS-0003 says you can use both HCPCS and NDC
Bottom page 38046
The absence of a code set standard would not preclude the use of NDC
for reporting drugs and biologics by covered entities on standard
transactions. Covered entities could continue to report drugs and
biologics as they preferred, for example, according to trading partner
agreements or as reported before the adoption.
Page 38048 (h)
and that HCPCS codes as well as NDC continue to be used in the standard
institutional and professional claim transactions.
Conflict:
The NDC NPRM CMS-0003 says you can use both NDC or HCPCS codes to
report drugs on a claim. The Addenda IG CMS-0005 New Note Added for N4
about J codes is specific to drugs administered through injection. The
J codes do not allow for oral medication.
Business Case:
California Department of Alcohol and Drug Programs (CADP) needs a
method to report methadone and other oral treatment medications in our
claims process.
Solution 1 - Currently there are no HCPCS codes that describe all of
CAPD medication treatments. We could request a generic HCPCS "H" code
from CMS for medications administration and further define the type of
drug, dose etc. in the new loop 2410 for drug identification.
Solution 2 - Several new HCPCS codes would have to be requested and
created for all of the specific types of drug medication treatment
claims that CADP processes.
Solution 3 - NDC codes could be required on the service line of claims
in the trading partner agreement between CADP and the counties
(providers).
Resolution:
A change is requested to the IG 837P Addenda CMS-0005
The 004010X098A1IG Addenda New Note Added - N4
(page 54 and page 77)
1) should be removed
2) or not be specific to HCPCS "J" codes.
3) or change the wording to state that NDC codes are required for
retail pharmacy claims and may also be used by others if defined in
their trading partner agreement.
Contact:
Laurie Valentine
Senior Consultant
Venturi Technology Partners
(916) 327-6373
[EMAIL PROTECTED]
Thanks,
Laurie Valentine
Venturi Technology Partners
CA Alcohol & Drug Programs
916-327-6373 cell 775-720-3789
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