On Friday, December 13, 2024, the Department of Health and Human Services (HHS) posted the Final Rule naming NCPDP Telecommunication Standard Version F6 as the next version of the standard to replace currently adopted Version D.0. Although the rule was posted on December 13th, the effective date of the Final Rule is Tuesday, February 11, 2025. This action takes place nearly two years after the proposed rule was posted on November 9, 2022.
Compliance with the Final Rule, meaning full implementation of Version F6 by all covered entities, is required Friday, February 11, 2028. This provides the industry with a full three years to comply. Also, the Final Rule provides for a transition period, beginning Wednesday, August 11, 2027, which is six months before the compliance date. During this time, all covered entities, based on agreements among industry trading partners, are allowed to use either version D.0 or F6 for transactions.
The Final Rule refers to the transition period as “8 months.” However, August to February is only six months. It is believed that HSS intended to provide eight months for the transition period and will be issuing a technical correction to the Final Rule in the near term. Based on that, PHSL believes the transition period will be June 11, 2027 to February 11, 2028, but readers should wait for HHS to issue the technical correction for the final word on those dates.
PHSL performed a cursory analysis of the differences between D.0 and F6 and found the following:
- 7 field name changes in the Request Segment
- 12 field name changes in the Response Segment
- 1 segment name change in the Response Segment
- 24 fields removed from the Request Segment, which includes the removal of 1 entire segment from the Request Segment
- 22 fields removed from the Response Segment
- 75 new fields added to the Request Segment – this does not include 21 new fields added in 3 new segments, which are situational for use in claim billing, encounter, eligibility verification requests, or for information reporting transactions
- 77 new fields added to the Response Segment – this does not include 45 new fields added in 3 new segments, which are only used when applicable.
It is important to note that most of the changes noted above were made to versions approved and published between D.0 and F6 (many changes were made in Versions E.0, E.3, E5 and EB). Also, with version E5, NCPDP stopped using the “dot” between version and release, which is the reason there is not a “dot” between F and 6. Lastly, be aware that some documents will refer to version F6 as “VF6.”
For complete information, NCPDP members should go to the My NCPDP area of the NCPDP web site to access the Telecommunication Standard VF6 Implementation Guide, along with the appropriate data dictionary, external code list, and matrices. Also refer to the Final Rule for more information regarding F6 and for information regarding the adoption of NCPDP Batch Standard Implementation Guide version 15 and the NCPDP Batch Standard Subrogation Implementation Guide version 10. Please let PHSL know if you have any questions we can assist with.