yes. I would count it as OTC meds.
Just this morning, I read some guidance from NAMAS (National Alliance of Medical Auditing Specialists) about RX vs OTC.
the main difference, per NAMAS, is that in order to count towards prescription drug management, "prescriptive authority is required. If it doesn't require prescriptive authority by the FDA, then Rx management is not met."
"Some medications come as both OTC & Rx, but the formulary and directions are the same. in this scenario, the risk of management would be OTC (the lower) as the FDA, by removal of prescriptive authority is noting this as OTC risk."
this was a view I had never seen before and I think, it is quite clarifying.
Nasal Saline can be bought over the counter and does not require a prescription.