Effective September 8, 2025
During a recent claims audit, Mountain Health Co-Op discovered that medical claims are being submitted without the required National Drug Code (NDC). The Deficit Reduction Act (DRA) of 2005 requires healthcare providers to submit manufacturer information for products administered in an office, clinic, hospital, or other outpatient setting. Since multiple NDCs can be linked to a single healthcare common procedure code (HCPC) or current procedural terminology code (CPT), using NDC numbers is crucial for accurately identifying the drug and manufacturer. This also helps ensure more precise payments and better management of drug costs for what was administered and billed.
Requirements
To comply with the DRA mandate, all physician-administered medications must have NDC information submitted on claims. NDC billing requirements will be enforced across all lines of business at Mountain Health Co-Op.
Starting September 8, 2025, all providers must include the 11-digit NDC and all other required information listed below when billing injections and other drug items on CMS-1450, UB-04 claim forms, and 837 electronic transactions.
- The applicable HCPCS or CPT code
- Number of HCPCS/CPT units
- The 11-digit NDC(s), including the N4 qualifier
- NDC unit of measurement (F2, GR, ML, UN)
- Number of NDC Units dispensed (must be greater than 0)
To ensure accurate and timely payments, you must provide the NDC information as described above when filing claims. Mountain Health Co-Op will reject any claim line items with service dates on or after September 8, 2025, if the necessary drug information is missing.
Additional Information
What is an NDC number?
It is a unique, 11-digit, 3-segment number that serves as the product identifier. The three segments are in a 5-4-2 format. The FDA uses it to track and identify medications. The three segments of the NDC code represent the labeler, the product, and the package size and type.
Where is the NDC located?
The NDC is found on the drug’s packaging, usually on the label or the outer packaging. It’s typically located near the barcode or the side of the box.
What codes require an NDC for reimbursement?
All drug-related HCPCS/CPT Level II codes, including, but not limited to:
- All J codes
- Drug-related Q codes
- Drug-related S codes
- Drug-related C codes
- Drug-related A codes
- Drug-related CPT codes
- Drug-related Rev codes
- Drug-related miscellaneous and unlisted codes
- Drug-related miscellaneous and unlisted codes
What codes require an NDC for reimbursement?
What All drug-related HCPCS/CPT Level II codes, including, but not limited to:
- All J codes
- Drug-related Q codes
- Drug-related S codes
- Drug-related C codes
- Drug-related A codes
- Drug-related CPT codes
- Drug-related Rev codes
- Drug-related miscellaneous and unlisted codes
Can I stop billing with HCPCS/CPT codes?
No. You must still submit the appropriate HCPCS or CPT codes along with the units of service, modifier(s), and charges on the claim form. Claims will be denied if all the required information is not provided.
Are NDC units the same as HCPCS units?
No. NDC units and HCPCS units are not the same. You will continue to bill HCPCS units the same.NDC units are the numeric quantity administered and the units of measurement (UOM). The UOM codes are:
- F2: International Unit (Products described as IU/vial or micrograms)
- GR: Grams (ointments, creams, inhalers, or bulk)
- ML: Milliliter (liquid, solution, or suspension)
- UN: Unit (powder-filled vials for injection)
- ME: Milligrams (this is a recognized billing qualifier used to identify milligrams; however, drug costs are generally recognized by UN or ML. If billing by milligrams, it is recommended that the claim be billed in an equivalent decimal format of grams (GM).
What if the NDC number does not contain 11 digits?
Billing NDC units is different than calculating HCPCS units. It is critical that you calculate both correctly. To calculate NDC units for billing purposes, start by confirming the drug’s 11-digit NDC, then determine the quantity dispensed and the appropriate UOM. NDC units are calculated by converting the amount dispensed into the correct unit of measure based on the drug form.
Can you help me calculate NDC units?
Billing NDC units is different than calculating HCPCS units. It is critical that you calculate both correctly. To calculate NDC units for billing purposes, start by confirming the drug’s 11-digit NDC, then determine the quantity dispensed and the appropriate UOM. NDC units are calculated by converting the amount dispensed into the correct unit of measure based on the drug form.
| Dosage Form | UOM | How to Calculate | Example |
| Oral Liquid | Milliliter (ML) | Use total ml dispensed | 240ml = 240 NDC Units (ML) |
| Injectable Vial | Milliliter (ML) | Use total ml dispensed | 10mls = 10 NDC units (ML) |
| Creams | Gram (GM) | Use total grams dispensed | 60gm tube = 60 NDC units (GM) |
| Injectable Vial | Unit (UN) | Use total vials dispensed | 1 vial = 1 NDC unit (UN) |
If the UOM used by the pharmacy system or prescriber differs from the one required for billing NDC units, you must convert the quantity dispensed into the correct UOM. See the two examples below.
| Strength | 25mg/ml |
| Dose | 100mg |
| UOM | ML |
| Convert to ML | 100mg ÷ 25mg/ml |
| NDC Units | 4 |
| Strength | 50mg/ml |
| Dose | 150mg |
| UOM | ML |
| Convert to ML | 150mg ÷ 50mg/ml |
| NDC Units | 3 |
What if I do not include the NDC or other related data in my claim?
Any professional drug claims billed on or after September 8, 2025, will be denied if they are missing the NDC number or any required processing information. Mountain Health Co-Op will deny any service lines associated with the missing information, and a corrected claim will need to be submitted for payment.
Examples
Example 1
| HCPCS Code | J2357 |
| HCPCS Description | omalizumab, 5mg |
| How Supplied | 150mg single-dose vial for reconstitution |
| NDC Code | 50242-0227-01 |
| Patient Dose | 150mg |
| How to report on CMS-1500 form | N450242022701 UN1 |
- NDC: 50242-0227-01
- Qualifier: N4
- One space
- Unit of Measure: UN
- Quantity of NDC units administered: 1
Example 2
| HCPCS Code | J9400 |
| HCPCS Description | ziv-alfibercept, 1mg |
| How Supplied | 200mg/8mg (25mg/ml) |
| Patient Dose | 400mg |
| NDC Units | 3 |
| How to report on CMS-1500 form | N450242022701 ML16 |
- NDC: 00024-5841-01
- Qualifier: N4
- One space
- Unit of Measure: ML
- Quantity of NDC units administered: 16