Comment

Tighten up the applicable starter sets

The various identified "starter value sets" in this section presents a confusing overlapping collection. The three items listed as "representing drug classes" are not equivalent and only the SNOMED CT (SCT) Product hierarchy is actually aligned with actual drug class concepts. SNOMED CT Drug product class concepts are uniquely valuable because NLM links SCT product class concepts to the appropriate RXNorm drug ingredients to support Drug class to RxNorm or even NDC codes identification via available APIs at RxClass. The other two suggested sets (Common Drug Classes for Allergy and Intolerance documentation and Common Drug Substances for Allergy and Intolerance documentation) do not represent useful drug classes and should not be listed in the Drug Classes for Allergy and Intolerance documentation section. For the Representing Medication section, the listed set Clinical Drug Ingredient (2.16.840.1.113762.1.4.1010.7) (RxNorm ingredient codes) is a subset of all potential drug ingredient RxNorm codes that was based on a historical review of common drug ingredients listed as causes of allergy or intolerance in clinical records done a number of years ago. While this list has not been updated, it is useful. I suggest adding to the suggestions in this section the set you will remove from the "class" set as it is the list of every ingredient or related code type in RxNorm - over 25,000 codes. This is the Common Drug Substances for Allergy and Intolerance documentation (2.16.840.1.113762.1.4.1186.1) set.

NCPDP Comments

NCPDP supports ONC’s recommendations.