Prescription Drug Management

jkottarathil

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Lindstrom, MN
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Hello all,

I have a question in regards to prescription drug management for MDM purposes that myself and other coders in our department have been questioning back and forth for a few months. We work exclusively in the domiciliary and home setting
(95/97 guidelines). The patients our providers provide "in-home" care for are in assisted living facilities and independent living facilities.

We constantly see it where the providers are writing prescriptions for OTC medications (for multiple reasons--a higher dosage of ibuprofen/Tylenol that you cannot get OTC, another example would be prescribing melatonin and getting it from the pharmacy rather than OTC). Our patient population typically does not leave their home setting. Their medications are managed by the primary care provider and ALF nursing staff (nursing coordinates with pharmacy). Here's an example, the patient is confined to their home. Our medical provider wrote this order: Refill: Tab-a-Vite 1 tab per G tube once daily. 30 days, Refills: 11, Qty: 30. Nursing staff sent the order to the patient's pharmacy.

Our question is even though they are OTC drugs, since we are prescribing them and it is coming from the pharmacy are we able to count this as prescription drug management for MDM purposes? Or would we have to drop it down to low risk for OTC drug management?
 

amyjph

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457
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Munising, MI
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In my opinion this would constitute prescription drug management. They are managing it, making decisions and the pharmacy is involved. Even if the drug is available OTC, they are prescribing it and it's part of the MDM. They are also considering it along with all the other medications and conditions the patient may have.

I found this on FCSO:

E/M FAQ -- What constitutes prescription drug management?

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".

NGS says:
  1. Please define prescription drug management relative to MDM.
Answer: In order to count prescription drug management there must be:

  1. A prescription drug that the practitioner is evaluating the appropriateness of using for the patient; and/or continuing to prescribe for the patient.
  2. Documentation on the prescription drug(s) that are being considered and the reason why they are being considered.
  3. Documentation of a practitioner’s decision to discontinue a prescription drug or to adjust the current dosage relative to changes in a patient’s condition.
  4. The patient condition, possible adverse effects, potential benefits, etc. of the patient using this prescription drug.
Prescription drug management is based on the documented evidence that the provider has evaluated medications during the E/M service as it relates to the patient’s current condition. Simply listing medications that patient takes is not prescription drug management. Credit will be provided for prescription drug management as long as the documentation clearly shows decision-making took place in regard to those medications.

Novitas: https://www.novitas-solutions.com/webcenter/portal/MedicareJL/pagebyid?contentId=00005056
4. 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.
 

TThivierge

Expert
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Lithonia, GA
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Hi JKott💊:)
I agree with Amyjh. The providers are managing it but also include the Z dx codes of Z76 or Z51.81 as last dx code according to managing or prescribing medications documented in their daily notations.
Lady T
 

jkottarathil

Contributor
Messages
16
Location
Lindstrom, MN
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In my opinion this would constitute prescription drug management. They are managing it, making decisions and the pharmacy is involved. Even if the drug is available OTC, they are prescribing it and it's part of the MDM. They are also considering it along with all the other medications and conditions the patient may have.

I found this on FCSO:

E/M FAQ -- What constitutes prescription drug management?

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".

NGS says:
  1. Please define prescription drug management relative to MDM.
Answer: In order to count prescription drug management there must be:

  1. A prescription drug that the practitioner is evaluating the appropriateness of using for the patient; and/or continuing to prescribe for the patient.
  2. Documentation on the prescription drug(s) that are being considered and the reason why they are being considered.
  3. Documentation of a practitioner’s decision to discontinue a prescription drug or to adjust the current dosage relative to changes in a patient’s condition.
  4. The patient condition, possible adverse effects, potential benefits, etc. of the patient using this prescription drug.
Prescription drug management is based on the documented evidence that the provider has evaluated medications during the E/M service as it relates to the patient’s current condition. Simply listing medications that patient takes is not prescription drug management. Credit will be provided for prescription drug management as long as the documentation clearly shows decision-making took place in regard to those medications.

Novitas: https://www.novitas-solutions.com/webcenter/portal/MedicareJL/pagebyid?contentId=00005056
4. 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.
I've been meaning to respond to this for weeks, but I keep forgetting. Thank you so much for this information! This was very very helpful! A+ answer!
 
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