As
@natashalage pointed out, we are discussing the risk level only here since that is the only information provided.
An OTC med written as an rx by the provider would almost always still be low risk. If the reason is simply to have insurance cover an OTC med, or because pseudoephedrine is used to make meth, so it is being monitored, neither of those things actually increase the patient's risk (unless they are actually making meth with it).
I did find this
AAFP reference:
If you are billing based on MDM, you can include decisions about prescription medications, but over-the-counter (OTC) medications generally don't meet moderate complexity. If you use OTC medications in that context, just state why the decision was higher risk. A prescription for an OTC medication for insurance coverage purposes does not meet this threshold.
Summary - it is possible for an OTC med to be moderate risk, but that complexity must be sufficiently documented.
Real world personal example: I wound up with a lateral condyle compression fracture of my femur a few months back (don't think you'll remember how to skateboard if you're over 40+ and not Tony Hawk). I was taking ibuprofen in prescription amounts. I don't think my orthopedist should be credited with "prescription drug management" because he asked if I wanted an Rx or just take more tabs of OTC advil. Now, if I had multiple co-morbidities, history of ulcer, taking a blood thinner, etc. and he needed to carefully tritrate or adjust how much OTC ibuprofen I was taking, then yes, moderate risk. Otherwise low risk.