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CMS and prescription drug management

  1. #1
    Overland Park, KS
    Default CMS and prescription drug management
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    I read in a physician magazine that CMS has stated that writing a prescription for a seven to ten day supply of an antibiotic is not considered to be a moderate complexity. Does anyone know about this and can anyone point me to this guidance, please? Thanks
    Dawson Ballard, Jr., CPC, CEMC, CPMA, CCS-P, CPC-P, CRHC, AAPC Fellow

  2. #2

    Where did you see this info at? I can't find anything from CMS supporting this.

    It honestly doesn't even make sense to me. It shouldn't matter how long you give a rx for. It only takes one dose to potentially kill someone that is allergic.

    Laura, CPC, CEMC

  3. #3
    Overland Park, KS
    I found it in Physician Practice Magazine in the Coding Q & A section. Here is the link. It is listed under prescription drug management.
    Dawson Ballard, Jr., CPC, CEMC, CPMA, CCS-P, CPC-P, CRHC, AAPC Fellow

  4. #4
    Very interesting. I have emailed Bill asking him to provide me with the CMS reference. I will update if/when I get a response.


    Laura, CPC, CEMC

  5. #5
    I got a response from the author Bill Dacey, below is the response I got.

    "Hi Laura - thanks for writing. I looked at what I had written - and either I wrote it incorrectly or it was edited a bit - could easily have been me.

    CMS central has not said that. Various carriers have said it in various ways. Not only have carrier medical directors and policy managers stated that, but when you look at their guidelines you can see it.

    I'm going to attach one of those guidelines - from Trailblazer. Look at the table A1. The first and subsequent options indicate different weights relative to how management is documented, how many drugs are managed. I'll also include an interim version of one of the AMA Tables of Risk - that places certain Rx management at level 3.

    You are correct though - 'CMS' didn't say that - but their agents do"

    I can't post the attachments but if anyone is interested in them let me know and I can email them.

    Laura, CPC, CEMC

  6. #6
    North Carolina
    Personally, this article doesn't persuade me to change my/our method of scoring physician documentation. Our carrier (to my knowledge) has never made any statements to support this articles view. To say that antibiodics don't qualify for RX mgmt (moderate complexity) is very odd to me. It certainly isn't OTC medication.... The physician needs to be credited for the congitive labor involved for determining the correct type of antibiodics, dosage, interactions, etc.... I think this is just another attempt to restrict physician reimbursement by micro-managing their every move. I know my physicians could certainly argue a good case.....
    Rebecca CPC, CPMA, CEMC

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