We have detailed who can perform computerized provider order entry (CPOE) for meaningful use objectives, as well as the potential costs of improper CPOE. Naturally, the broader question in this discussion is why only licensed health care professionals or credentialed medical assistants are allowed to perform CPOE.
These rulings are made with patient protection as the primary goal. One way the limits on CPOE help ensure that protection involves a function of the CPOE system known as clinical decision support alerts.
Robert Anthony of the Centers for Medicare and Medicaid Services spoke about these alerts and their importance for patient safety in his presentation. The full text and video are below:
“The purpose of this really is to make sure that when information goes into a system, and it is done obviously prior to any action being taken on the orders … that somebody who has some clinical expertise or authority is able to see any of the clinical decision support alerts that pop up and say, ‘You may not want to prescribe this medication because of a counterindication.’ Then they can take action on that for patient safety, whereas I as a lay person might see a clinical decision alert, have no idea what that means, and ignore it completely. So that’s really the whole idea behind having a licensed health professional or a CMA (AAMA) to look at that.”
We have established who can perform computerized provider order entry (CPOE) for meaningful use objectives. However, what happens when someone other than a licensed health care professional or credentialed medical assistant performs CPOEand the provider counts the entry of these orders for meaningful use? Would the provider in question be penalized for such an error?
The presentation by Robert Anthony of the Centers for Medicare and Medicaid Services (CMS) helps illuminate the situation. Essentially, CMS would not levy a direct penalty against the provider, but the order in question could not be counted toward the meaningful use objective. This, in turn, could result in financial loss down the road. The text and video of Mr. Anthony’s response is below:
It’s not a penalty, but you wouldn’t be able to count those people as part of meaningful use for CPOE. … If I as a lay person go through and I complete a medication order, [CMS does not] have any jurisdiction over whether that is allowed, although there may be some local or state regulations that would cover that. As far as meaningful use is concerned, it means that you couldn’t count that order within the numerator of that particular objective. So it is possible that because of how that is calculated you might not meet that particular threshold for that objective. But it’s not a penalty that we apply for it—it’s just that you couldn’t count those orders toward the actual meaningful use objective.
As indicated in my Public Affairs article in the July/August 2013 CMA Today, an eligible professional must meet all Core Objectives. Failure to meet any one Core Objective would result in no incentive payment.
As discussions about the CMS Stage 2 rule continue, one question that persists is whether non-credentialed medical assistants–and by extension, lay people–can enter orders into the electronic health record (EHR). What entries can such workers make, if any?
Robert Anthony of the CMS Health IT Initiatives Group touched on this topic during our joint presentation at last year’s AAMA Annual Conference. In short, the only meaningful use objective that carries a requirement as to who physically enters orders is computerized provider order entry (CPOE). The full text of Mr. Anthony’s response follows, with video:
For all of these objectives except computerized provider order entry, there really isn’t a requirement about who enters that information into an EHR, or who takes a particular action at all. Anybody can really do that. The only objective that there are any requirements around who does the actual entering for the EHR is that CPOE.
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There are two different processes here. One is for entering something like blood pressure, or height/weight. Anybody can do that. Absolutely anybody can do that. In fact, there are many systems that are part of larger organizations where they’re not entering that information at all;they’re actually getting that information from another system, especially demographic information that’s being loaded from a practice management system automatically. But when it comes to CPOE, we are very specific about who enters that information. The information either has to be entered by a licensed health care professional–and has to be done prior to any action being taken on the order–or it has to be entered by a [credentialed] medical assistant. You can’t have a lay person who enters that, somebody who goes through and just clicks a button. You have to have the actual licensed health care professional or [credentialed medical assistant].
I have been receiving questions about whether a medical assistant who formerly held the CMA (AAMA) credential is considered by the Centers for Medicare and Medicaid Services (CMS) to be a “credentialed medical assistant,” and is permitted to enter medication, laboratory, and radiology orders into the computerized provider order entry (CPOE) system for “meaningful use” calculations under the Medicare and Medicaid Electronic Health Records Incentive Programs.
First of all, it is important to understand that the policy of the Certifying Board of the AAMA states that only a current CMA (AAMA) is permitted legally to use the initialisms “CMA” or “CMA (AAMA),” and the phrases “Certified Medical Assistant” or “certified medical assistant.” Anyone other than a current CMA (AAMA) who does so is violating the intellectual property rights of the American Association of Medical Assistants.
Because an individual whose CMA (AAMA) is not current cannot use the credential for any purpose, such an individual is not a “credentialed medical assistant” according to the CMS rule, and cannot enter orders into the CPOE system and have such entry count toward meeting the meaningful use requirements. The individual must recertify and make current the CMA (AAMA) credential in order to meet the CMS definition of a “credentialed medical assistant.”
On March 19 the Public Health Committee of the Connecticut legislature held a public hearing on General Assembly Raised Bill No. 459, “An Act Concerning Medical Assistants.” This legislation was the result of a scope of practice request submitted by the American Association of Medical Assistants and the Connecticut Society of Medical Assistants (CSMA) on July 16, 2012, to the Connecticut Department of Public Health (as described in the March/April 2013 issue of CMA Today).
Raised Bill No. 459 would permit physicians to delegate to medical assistants who had graduated from an accredited postsecondary medical assisting program and who are certified by the Certifying Board of the AAMA “the administration of medication orally, by inhalation, or by intramuscular, intradermal, or subcutaneous injections, including, but not limited to, the administration of a vaccine.” The bill would also require that the medication be administered “under the direct supervision, control, and responsibility of a physician who is in the outpatient clinic or office when such medication is administered.”
The AAMA and the CSMA submitted joint written testimony in support of Raised Bill No. 459, and Holly Martin, CMA (AAMA), of the CSMA, presented oral testimony at the March 19 hearing. Legal Eye will keep readers informed about the outcome of Bill No. 459.