Wiki 2021 E&M guidelines. OTC vs Rx

wynonna

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I'm looking at AMA audit tool and notice there is no designation between OTC and Rx.
Is this because OTC can be more complicated (moderate MDM) depending on patient's co-morbidities?
For example. a patient come in with Diabetes or Hypertension. Our provider recommends OTC, but has to double check OTC against Metformin or hypertension scripts which pt takes. This seems to be b/c pt blood sugar in DM can be raised or lowered with OTC, or another pt with Hypertension may have blood pressure increases with OTC, so there is moderate risk, not just low MDM.
Am I understanding this right?
 
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