Does anyone have a reliable source of information on this topic? I am an auditor and have run into conflicting views on this. Some want to give credit for prescription drug management under the risk MDM and others believe it should be low, when the MD write a prescription for any OTC drug in the emergency room. What I have located appears to state any medication that can be purchased over the counter, should be considered just that - OTC and low risk. I can't seem to find a definitive answer on this.....another one of those grey areas??