Healthcare Purchasing News (HPN): Why should healthcare leaders treat the transition to 12-digit National Drug Codes as an enterprise-wide initiative rather than solely a pharmacy or IT project? 

Carolyn Liptak: The NDC is embedded in virtually every medication-related workflow across a health system. It affects purchasing, dispensing, billing, quality reporting, claims processing, electronic health records, pharmacy systems, revenue cycle applications, and the interfaces connecting them. A failure in one area can create downstream disruptions across the organization.  

HPN: Which health system departments, technologies, and medication-related workflows will be most affected?  

Liptak: The transition will affect pharmacy operations, supply chain and purchasing, revenue cycle and finance, quality reporting, and information technology. The technologies involved include EHRs, pharmacy management systems, revenue cycle applications, claims processing platforms, system interfaces, and barcode scanning technologies. 

The affected workflows extend from purchasing, receiving, and inventory management to dispensing, medication administration, billing, reimbursement, and quality reporting. Because those functions are interconnected, organizations need to assess the entire medication-use process rather than focus on a single department or application.  

HPN: What patient safety risks could arise if systems cannot consistently recognize, exchange, or scan 12-digit NDCs?  

Liptak: The most significant concern is that inconsistent support for 12-digit NDCs could break the electronic verification chain that helps ensure the right drug reaches the right patient at the right dose and time. Potential consequences include barcode scanning failures, incorrect medication mapping between systems, missed clinical alerts, impaired recall management, and greater reliance on error-prone manual workarounds.  

HPN: What operational and financial consequences could health systems face if they delay preparation?  

Liptak: Delayed preparation could cause disruptions throughout medication-use workflows, including barcode scanning failures, manual receiving and processing, inventory reconciliation problems, claims rejections, and reimbursement delays. Organizations also could face higher labor, project, and consulting costs, along with greater competition for limited vendor and consulting resources. 

Waiting also could force organizations to compress implementation into the years immediately preceding the deadline. Beginning early gives them the flexibility to spread costs and resources across multiple budget cycles.  

HPN: What should organizations begin doing now, even though the March 7, 2033, transition date may appear distant?  

Liptak: Seven years allows time for preparation, but not for delay. Organizations should begin assessing the transition’s impact, planning budgets, establishing governance, engaging vendors, evaluating workflows, and conducting early testing. Starting now can reduce risk and help avoid costly last-minute implementation challenges.  

HPN: Who should lead the initiative, and which departments should participate in its governance? 

Liptak: The transition should be managed through an executive-sponsored, cross-functional governance structure rather than assigned solely to pharmacy or IT. Depending on the organization, an executive steering committee could be sponsored by the chief operating officer, chief information officer, chief pharmacy officer, or chief clinical or medical officer.  

The governance team should include leaders from pharmacy, information technology, supply chain, revenue cycle, finance, nursing, quality, patient safety, compliance, and project management. The transition simultaneously affects clinical, operational, financial, and technology workflows, so no single department has authority over its entire scope.  

HPN: How can health systems identify every system, interface, device, and workflow that currently depends on the 10-digit NDC?  

Liptak: Vizient recommends beginning with a comprehensive discovery phase and workflow assessment. Organizations should inventory and evaluate every medication-related system, interface, device, workflow, and technology that uses NDC data. That inventory provides the foundation for identifying dependencies, assigning ownership, and developing an implementation plan.  

HPN: What questions should organizations begin asking technology vendors, distributors, and manufacturers?  

Liptak: Organizations should ask whether each vendor is prepared to support 12-digit NDCs, which products and interfaces will be affected, and when necessary upgrades will become available. They also should clarify testing requirements, implementation timelines, support responsibilities, and any associated costs. Those conversations can reveal dependencies and resource needs that may not be apparent during an internal assessment.  

HPN: What challenges could emerge while 10- and 12-digit NDCs are both in circulation?  

Liptak: Organizations could encounter significant inconsistencies if some systems recognize 12-digit NDCs while others do not. EHR and billing applications may not be updated at the same time, while barcode scanners, pharmacy automation, automated dispensing cabinets, and inventory management systems could fail to process certain formats. Inventory records may not reconcile correctly, claims may be rejected, and IT teams may need to develop temporary fixes to keep workflows operating.  

HPN: How should organizations test the entire medication-use workflow instead of evaluating individual systems in isolation?  

Liptak: Testing should follow medications and NDC data through the end-to-end medication-use process, examining how systems, interfaces, and departments interact rather than validating individual applications independently.  

One of the major challenges is that organizations will likely need to support FDA 10-digit NDCs, HIPAA 11-digit NDCs, and the new FDA 12-digit NDCs simultaneously during the transition, and continue supporting older formats for historical records afterward. That complexity reinforces why application-level testing alone is insufficient. Organizations must confirm that data can move accurately through complete workflows.  

HPN: How can health systems phase technology, labor, and consulting investments across multiple budget cycles?  

Liptak: Organizations that begin planning now can distribute spending over several years. They can phase investments in technology, project management, workflow redesign, testing, change management, vendor support, and consulting services. Starting early reduces the likelihood of an expensive, compressed implementation close to the deadline.  

HPN: If an organization has not started preparing, what are the first three actions it should take?  

Liptak: First, conduct a discovery process and inventory every system, device, and workflow that depends on NDC data. Second, establish executive governance and a cross-functional leadership team. Third, begin vendor readiness discussions while developing a long-term budget and end-to-end testing strategy. Those steps will give the organization a clear view of its exposure and a structure for moving forward.