E/M Audit - prescription drug management

Donna Tabor

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I do auditing for our Family Practice Clinic, my understanding is that if the physician "prescribed" over the counter medicine that this is a credit for moderate level. I was told this by an auditing firm that came in to our facility, but I can not find this in writing - can anyone help is this correct?:)
 

Lisa Bledsoe

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This is incorrect. It has always been my understanding that to count as moderate risk the "prescription" must be something not over the counter. I would not count "prescribed OTC meds" as moderate risk. If you look at the table of risk, over the counter drugs are low risk.
 

ARCPC9491

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I agree with Lisa. OTC drugs are low on the table of risk. Prescription drug management is an rx from a pharmacy...
 

LLovett

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It can be moderate for OTC drugs

If the doctor prescribes the patient an over the counter drug but tells them to use it at prescription strength then they should get credit for prescription drug management.

One of the most common ones I have seen this done with is Ibuprofen.

Documentation must support they advised the patient to take it at a prescription level in order to qualify.

Laura, CPC
 
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In order to accurately differentiate an OTC medication from a prescription medication you must look at the dosage. Ibuprofen(Motrin) for example, a dosage of 400mg and above is considered prescription strength. If the provider is prescribing a dosage this high he is performing prescription drug management in his medical decision making, therefore the level of risk would be considered moderate. A prescription drug has to be written by a physician and administered by a pharmacist, because it has the potential to be stronger, more complicated, and/or more dangerous than OTC dosage. There is a higher risk of an adverse reaction, or complication involving other medications that the patient may be taking.
 

hunters

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My only thought/response to that is a physician can order a patient to take say 600mg motrin (prescription strength), but that dosage can still be taken with the OTC motrin simply by taking 3 of the 200mg tablets at a time. Frequently, we have patients that are on Medicaid who request a prescription for motrin only so they won't have to pay for it OTC. Just because they are getting a prescription for Motrin, which can be purchased OTC, should not make it Moderate Level of Risk. We categorize these as Low.
 

CatchTheWind

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See page 20 of Medicare Learning Network's "Evaluation and Management Services Guide." Over the counter medications are listed under "low risk."
 
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