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-