I disagree. I believe the drug and the dosage must be linked by the provider to a dx, and be specifically documented.
per
Noridian - Ask the Contractor Q&A (emphasis added by me):
Q7. What are the guidelines regarding prescription drug management in the MDM?
A7. Credit is given for prescription drug management when documentation indicates medical decision making for the management of a prescription drug by the physician who is rendering the service. Medical management could include a new drug being prescribed, a change to an existing prescription, verification of any side effects or problems with the drug, or simply refilling a current medication.
The drug and dosage must be documented as well as the drug management.
per
First Coast (emphasis added by me):
Q. During an evaluation and management visit, what constitutes "prescription drug management?"
A. "Prescription drug management" is
based on documented evidence that the provider has evaluated the patient's medications as part of a service. This may be a prescription being written or discontinued, or a decision to maintain a current medication or dosage.
Note: Simply listing current medications is not considered "prescription drug management."
"Prescription drug management" does differ from "drug therapy requiring intensive monitoring for toxicity".
Per the CPT definitions, "drug therapy requiring intensive monitoring for toxicity" is for a drug requiring intensive monitoring which is a therapeutic agent with the potential to cause serious morbidity or death. The monitoring is performed for assessment of these adverse effects and not primarily for assessment of therapeutic efficacy. The monitoring should be that which is generally accepted practice for the agent but may be patient specific in some cases. Intensive monitoring may be long-term or short term. Long-term intensive monitoring is not less than quarterly. The monitoring may be by a lab test, a physiologic test or imaging. Monitoring by history or examination does not qualify. The monitoring affects the level of medical decision making in an encounter in which it is considered in the management of the patient. Examples may include monitoring for a cytopenia in the use of an antineoplastic agent between dose cycles or the short-term intensive monitoring of electrolytes and renal function in a patient who is undergoing diuresis.
Examples of monitoring that does not qualify includes monitoring glucose levels during insulin therapy as the primary reason is the therapeutic effect (unless severe hypoglycemia is a current, significant concern); or annual electrolytes and renal function for a patient on a diuretic as the frequency does not meet the threshold.
per
Noridian - FAQs - E/M (emphasis added by me):
When can prescription drug management be credited in the medical decision-making risk of complications chart?
Credit is given for prescription drug management when documentation indicates medical management of the prescription drug by the physician who is rendering the service. Medical management includes a new drug being prescribed, a change to an existing prescription or simply refilling a current medication.
The drug and dosage should be documented as well as the drug management.
If medications are just listed in patient’s medical record, credit is given for past history.