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Thread: prescription drug management

  1. #1

    Default prescription drug management

    AAPC: Back to School
    If your doctor gives a prescription for something that is typically over the counter, like anamantle cream, can you count this as "prescription drug management" under the table of risk?

    I have heard two different opinions on this, and I'm curious what everyone else thinks...

  2. #2
    Join Date
    Apr 2007
    North Carolina


    I really think this is a judgement call. I presented this question to our local Medicare director and it boils down to the documentation and the relationship to the presenting problem. Recently, I attended the auditing workshop (AAPC) and one of the case examples we went over counted the OTC prescribed RX (600 mg's) as prescription mgmt.

  3. #3


    I work for a company that uses the computer to code and every RX is counted as moderate risk. No matter what.

  4. #4


    I have to disagree. If the drug is available OTC then it is not a prescription drug. The physician can write a prescription for anything.

    Why would an OTC be written as a prescription? Convenience for the patient? Money/cost benefit? I know its cheaper for me to get an RX with copay than it is to go buy it OTC at the store. I know in auditing military records, all drugs were ordered as an RX because then there was no out-of-pocket cost to the member

    Prescription drug management is for "RX only" drugs. Not for OTC drugs. The moderate "management" isnt decided based on what piece of paper the order is written on it's based on the higher level of MDM for drug, dose, interaction, monitoring etc

    And I really don't want to argue with a RAC auditor that 100mg Ibuprofen is really an RX drug.

  5. #5
    Join Date
    Apr 2007
    North Carolina


    I don't see this issue as a "black and white" issue...

    Many times, the initial treatment of pain is an OTC analgesic, either through patient self-medication or physician direction. The variety of OTC necessitates that physicians be knowledgeable about the strengths, limitations and common pitfalls of OTC analgesics. Like any medication, there can be serious side effects if taken inappropriately; GI side effects, renal toxicity, etc. Patients with pre-existing renal impairment (CHF, cirrhosis, etc), are at high-risk for renal toxicities. Some patients may assume that because they are sold without a prescription, OTC analgesics are “safe,” and thus, may think that doubling or tripling the dose to prescription levels is also safe. We have a moderate geriatric population and many find selecting the correct OTC analgesic confusing which can led to misuse; especially when combined with their other medications or herbal remedies. With proper documenation that outlines the potential risks involved, I feel my physician could argue his case if an outside auditor intially disagreed crediting an OTC RX as RX mgmt.

    Just my take-

  6. #6


    Under the table of risk management options over-the-counter drugs is listed under Low risk. If the only way the patient can get the med is with a RX I would count it as moderate.

  7. #7

    Default What is a Prescription

    My take had always been the OTC drugs don't count toward moderate risk which will usually get you to a higher E&M. But the argument I've heard in recent yearss is that a non prescription med like aspirin or Ibuprofin can be part of a moderate or high risk scenario such as impending MI in adult or high fever in a child. But there should be some documentation with dosage etc by the physician that looks like a prescription. The other argument is that there are many meds that are now OTC that were prescription for a long time. So where do you draw the line.


  8. #8
    Join Date
    Apr 2007


    We counted the Rx for an OTC med if it was a dosage that required a prescription. Ibuprofen, for example, wouldn't be counted if it was 200mg but if it was a 600mg or 800mg dosage, it would be.
    Pam Tienter, CPC, COC, CPC-P, CCS-P, CPMA, CPC-I
    AHIMA Approved ICD-10-CM/PCS Trainer
    AAPC National ICD-10-CM Trainer

  9. #9


    I myself do not give the Moderate if it is truely an OTC drug. I spoke with a doctor and even he agrees. Even if they are scipting 600 or 800mg Ibuprofen still low if it comes down to the scipt being the deciding factor, if it can be bought OTC then thats that. Low in my opinion anyways.

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