We often spend a lot of time talking about prescription drug management. Today in our “Take” we will spend time addressing over-the-counter medication. This question was submitted to me by Kelly, who works in a dermatology practice, but her question is relevant no matter your specialty.
Kelly’s question is about a physician who is using an over-the-counter medication at a higher than OTC dose to treat a patient with urticaria, recommending a regimen of 2-3 Allegra at night, plus Benadryl. (Oh my! I don’t think I’d wake up the next morning!) This isn’t the usual amount of over-the-counter medication that a patient would take, and the physician is stating they should get credit for this encounter as if this is prescription drug management. Of course, the auditor is stating these are not prescription drugs, and the physician is not using prescriptive authority; therefore, this cannot be ruled as prescription drug management. I have to say, TIME OUT! Everyone…keep in mind that in the third column of medical decision-making, we are not scoring the treatment plans. Remember what the header of column three says –risk of complications of the patient management or treatment that is rendered or is being considered for that patient. What we need to see from this physician is the documentation and to know what the risks are for this patient taking that dosage of off-brand medication. This is not an FDA-approved dose, so I would expect that the documentation would mimic that is the case. So, what is the physician documenting that are the impending risks for this patient? My presumption as a non-clinician would be based on the MDM charts. (By the way, NAMAS has created revised MDM charts for auditors that include lay terms and additional guidance available on our website or in our shopping cart. These are free downloads, whether you get them on our website or in our shopping cart.) These charts show you that risks are either average, below average, or above average. When we consider the risk of a patient using an over-the-counter medication off-label, that would certainly not be low or below average risk. That would be at least average risk of a typical encounter corresponding with what this provider indicates. The thing is, we can’t get locked into the examples that the AMA has given us, which are “Prescription Drug Management,” and “Decision for Surgery”… remember those are examples only, and the reason they’re examples only is because this category is the risk of managing those patients. The risk of managing this patient is the off-label management which is a higher level of risk than managing the patient on straight over-the-counter treatment, and for that reason, if documented appropriately to validate such risk, it would be a higher level of care. When considering the third risk (we are always considering the risk), our providers need to understand when documenting the treatment plan, it is not just documenting the treatment plan, it is called “assessment and plan”, but we really should be calling it the “evaluation of risk and treatment”. Realistically, that’s what we should be calling this area for providers to help them better understand what should be included in the documentation.
I hope this segment has been helpful to you. Please make sure you check out the agenda for the NAMAS 2023 Virtual Conference coming up on April 5-6 and also all of our resources on the NAMAS website.
Be sure to reach out to namas@namas.co if I can help you with any questions or comments!
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- Become a NAMAS Member to earn those CEUs and take advantage of learning resources, products, and resources!
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