"One area of the Table of Risk that has been hotly debated by coding professionals is the meaning of the term 'Prescription Drug Management,' which is listed as moderate risk in the management options category," says Jennie L. Campbell, consulting senior manager with Pershing Yoakley & Associates, a public accounting firm with offices in Knoxville, Tenn.; Atlanta; Tampa, Fla.; and Charlotte, N.C.
Campbell asked CMS about these concerns. Noting that the medical documentation must fully support the reasons and rationale for all prescriptions, a CMS policy contact provided the following examples of "Prescription Drug Management":
1. Writing a prescription;
2. Reviewing and not changing current prescription medications and dosages;
3. Discontinuing a prescription medication; and
4. Decision not to prescribe drug(s) that may cause potential side effects or interactions with current medications. "Further, it is clear from the background information provided by the CMS policy contact that a moderate risk level for prescription drug management can be assigned whenever a prescription drug has been prescribed for a patient," Campbell says. "It is not dependent on whether the drug is of short or long duration. 'Prescription Drug Management' can include an injection given in the office or an oral prescription drug that will be taken for two weeks."