Submitted by nradov on 2022-09-23 UHG comment on adding NDC UnitedHealth Group requests that ONC add the FDA’s National Drug Code (NDC) Directory as an Optional item in the Allergies and Intolerances class Substance (Medication) data element list of Applicable Vocabulary Standards. This would improve consistency with the Medications class Medications data element which already includes NDC in the list of Applicable Vocabulary Standards as of USCDI V3. Many electronic health record (EHR) and pharmacy applications store both medications and drug intolerances using NDC codes rather than RxNorm, and are unable to automatically convert patient data from NDC to RxNorm when sending data to external applications. While RxNorm is preferred for most use cases, for interoperability purposes it is always better to exchange coded data rather than unstructured text. Adding NDC as an option will enhance meaningful interoperability and improve patient safety by allowing automatic detection of potential adverse drug reactions during electronic prescription (eRx) workflows.