Medical Assistants Win Big in CMS Ruling

It thrills me to report that the Centers for Medicare and Medicaid Services (CMS) recently ruled that credentialed medical assistants are permitted to enter medication orders into the computerized provider order entry (CPOE) system.

This decision scores a great victory for medical assistants across the country. Previously, only licensed health care professionals—a group that excluded medical assistants—were allowed to perform entries into the CPOE system. Given that CMAs (AAMA) are formally educated in their discipline, have current certification from a national credentialing body, and have the knowledge and ability to enter orders into the CPOE system as directed by an overseeing heath care provider, the previous restrictions diminished not only the role of CMAs (AAMA) in the practice, but also the overall effectiveness of team-based care.

Prior to the ruling, the CMS considered a few different options. One option would have allowed “anyone, including those commonly referred to as scribes,” to enter orders into the medical record. The AAMA and the CMS both agreed this option would be unwise and risk exposing patients to substandard allied health services from unqualified professionals. Yet another option allowed for “any licensed, certified, or appropriately credentialed health care professional” to enter orders into the CPOE. The CMS decided this option was too broad, as well, since the concept of “credentialed health professionals” could include any number of workers with a similarly wide range of qualifications. In the end, the CMS made the decision to use the more limited description of including credentialed medical assistants.

Again, this is a great victory—and a great day—for medical assistants nationwide!

(Read the full CMS ruling as published in the Federal Register at http://www.gpo.gov/fdsys/pkg/FR-2012-09-04/pdf/2012-21050.pdf.)

About Donald A. Balasa

Donald A. Balasa, JD, MBA, executive director and legal counsel for the American Association of Medical Assistants, keeps his eye on what is happening in the profession.
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73 Responses to Medical Assistants Win Big in CMS Ruling

  1. Brewer, Sherry says:

    Well done Don! This is great news and once again I thank you for forwarding the cause of medical assisting.

    Sherry Brewer, BS, CMA-AC(AAMA)

    Medical Assistant Program Manager/Coordinator

    Cuyahoga Community College

    2900 Community College Avenue

    MHCS-124E

    Cleveland, Ohio 44115-3196

    Phone: 216-987-4439

    Fax: 216-987-4285

    • Elizabeth Peace, M.A. Program director Georgia says:

      Thank you Don. One more victory in our battle to educate the public and potential employers to the versatility and capabilities of your graduates.

  2. Don,
    AAMA and every CMA(AAMA) have a true hero in you.
    There have been countless situations where YOU have made the profession of medical assisting better in many ways.
    A simple “thank you” does not cover the appreciation I wish to express for your devotion and diligence.
    So here’s a quote:
    One can pay back the loan of gold, but one dies forever in debt to those who are kind. ~Malayan Proverb

    Respectfully,
    Doni

    Doniel (Doni) Noble, CMA (AAMA), RMA
    wsma.net@gmail.com
    http://www.WSMA.net
    Wisconsin Society of Medical Assistants (WSMA)
    WSMA.net Web Administrator

  3. Diane Albarella says:

    good news!!! Now, let’s try to become licensed here in NJ so as to raise prestige,awareness, and make the public aware of our talents. Especially now since Obama will win and healthcare will be patient oriented.Diane Albarella,B.A.,A.A.,A.A.S.,CMA

  4. One more wonderful reason for Medical Assistants to prove competency through credentialling.

  5. Linda says:

    Thank you,
    Can you direct me to where I could find in the CMS site?

  6. Leslie says:

    Congrat! Could you repost the CMS link – it does not appear to be working? Thanks!

  7. Tanell D. Clark, CMA (AAMA) says:

    Another battle won putting us closer to winning the war for respect! Awsome news!!!!

  8. Debbie Leanio CMA says:

    I find this to be wonderful news. I do wish also to be licensed in the state of IN because everyone wants cna’s or LPN’s. I am having a hard time finding work. But do keep up the good work.

  9. Vicki Sokolnik, CMA(AAMA) says:

    Don,
    Thank you so much for your persistence & expertise in making a difference for CMA’s. We owe you a great deal of gratitude. This is such a HUGE win for us and helps to prove to our employers the real value we give them and to our patients.
    I read in the ruling that this will be part of Stage 2 Meaningful Use, what would be the effective date that this change will be made?

    • You are welcome, Vicki, and thank you for your kind words!

      My interpretation of the CMS final rule is that it went into effect immediately upon publication in the Federal Register, which was September 4. An argument can be made that the rule will not go into effect until November 5, 2012. I do not think that the November 5 theory is the best understanding, but I will continue to study this issue. In any case, I find no basis in the rule to argue that the provision about credentialed medical assistants goes into effect any later than November 5 of this year.

      I hope this is helpful, Vicki. Please let us know how we can be of further assistance.

      Don

      Donald A. Balasa, JD, MBA
      Executive Director, Legal Counsel

      American Association of Medical Assistants
      Ph: 800/228-2262 | Fax: 312/899-1259 | http://www.aama-ntl.org

      Visit us on Facebook! http://www.aama-ntl.org/facebook

      The CMA (AAMA): Health Care’s Most Versatile Professional

  10. Melissa Burbage CMA (AAMA) says:

    Don,

    I work for a Pediatric office and I just want to make sure I understand all of this. Can a CMA order other test? Like Strep, Flu, RSV ect….. And can they order immunizations? I just want to make sure my office is doing everything right.

    • Thank you for your question, Melissa. It was good to see you and your South Carolina Society of Medical Assistants colleagues in Scottsdale.

      It is my understanding that the CMS final rule permits credentialed medical assistants to enter orders into the computerized provider order entry system for all of the procedures and tests you list below. Of course, credentialed medical assistants can enter such orders only as specifically directed by the overseeing/delegating/supervising physician.

      I hope this is helpful, Melissa. Please let us know how we can be of further assistance.

      Don

      Donald A. Balasa, JD, MBA
      Executive Director, Legal Counsel

      American Association of Medical Assistants
      Ph: 800/228-2262 | Fax: 312/899-1259 | http://www.aama-ntl.org

      Visit us on Facebook! http://www.aama-ntl.org/facebook

      The CMA (AAMA): Health Care’s Most Versatile Professional

      • Melissa Burbage CMA (AAMA) says:

        Don, That helps, Thanks. I do have another question. If I have staff that are not certified can they put in orders for the flu, strep, immunizations ect..under the doctors? I guess my question is what can a non certified MA able to do?

      • You are very welcome, Melissa! I am glad you found that helpful.

        Because of the CMS final rule, non-certified and non-credentialed medical assistants are not permitted to enter any orders into the computerized provider order entry system for purposes of having such order entry count as meaningful use of the Electronic Health Record (EHR) under the CMS Stage 2 rule for the Medicare and Medicaid Incentive Program. If the overseeing/delegating/supervising physician is not concerned about having such order entry count for meaning use, he/she is permitted to delegate order entry into the EHR to non-certified medical assistants.

        Is this responsive to your question, Melissa?

        Don

        Donald A. Balasa, JD, MBA
        Executive Director, Legal Counsel

        American Association of Medical Assistants
        Ph: 800/228-2262 | Fax: 312/899-1259 | http://www.aama-ntl.org

        Visit us on Facebook! http://www.aama-ntl.org/facebook

        The CMA (AAMA): Health Care’s Most Versatile Professional

  11. Christa says:

    this is great news, however what would be the ramifications if there non credentialed medical assistants doing this also? There are still many offices out there that do not require hiring CMA’s or other “credentialed medical assistant”. Thanks Don for all you do.

    • Lori Yakubek says:

      What are the other “credentials “allowed to document? We have registered MA’s

      • Thank you for your question. The CMS final rule states that medical assistants cannot have a “credential” issued by an employer. The RMA(AMT) would qualify as a medical assisting credential, in my opinion.

        Donald A. Balasa, JD, MBA
        Executive Director, Legal Counsel

        American Association of Medical Assistants
        Ph: 800/228-2262 | Fax: 312/899-1259 | http://www.aama-ntl.org

        Visit us on Facebook! http://www.aama-ntl.org/facebook

        The CMA (AAMA): Health Care’s Most Versatile Professional

    • You are welcome, Christa, and thank you for your kind words.

      If a non-credentialed medical assistant were entering orders into the electronic health record (EHR), such use of the EHR could not be counted toward meaningful use for purposes of the Medicare and Medicaid Incentive Program for EHRs.

      I hope this is helpful, Christa.

      Don

      Donald A. Balasa, JD, MBA
      Executive Director, Legal Counsel

      American Association of Medical Assistants
      Ph: 800/228-2262 | Fax: 312/899-1259 | http://www.aama-ntl.org

      Visit us on Facebook! http://www.aama-ntl.org/facebook

      The CMA (AAMA): Health Care’s Most Versatile Professional

  12. Kimberly Flowers, CMA (AAMA) says:

    I have been allowed to enter and send medications by E-scribe but, one of the physician assistants would always review and sign off the transaction officially. We do so much, get paid so little and need more respect!

  13. Laura Kassel, CMA (AAMA) says:

    My office has been replacing CMA’S and MA’S with LPN’S because of this rule. It has made me as a CMA feel like we are being pushed out of our Medical Group. I am happy something went in our favor.

  14. Cassie Deegan, CMA (AAMA) says:

    Don,

    I’m struggling to find the recent notation of “licensed or certified healcare professional” from the CMS link you provided above: It’s possible I skipped over it, considering it’s so large. Can you reference the update by page number?

    On page 294, Table 5: It still states, “Use computerized provider order entry (CPOE) for medication orders directly entered by any licensed healthcare professional who can enter orders into the medical record per state, local, and professional guidelines.”

    Thank-you!

    • Please see the following language on pages 69-71:

      Page 69
      Comment: We have received many comments on who can enter the order into CEHRT
      for it to count as CPOE. Four possibilities received comment support. First, only the ordering
      provider be able to enter the order into CEHRT. Second, any licensed healthcare professional
      who can enter orders into the medical record per state, local and professional guidelines can enter
      the order into CEHRT. This is the current policy which was proposed to continue. Third, an
      expansion to any licensed, certified or appropriately credentialed healthcare professional (some
      commenters replaced medical assistant with healthcare professional) who can enter orders into
      the medical record per state, local and professional guidelines. Fourth, an expansion to allow
      anyone, including those commonly referred to as scribes, enter the orders into the medical record
      per state, local and professional guidelines. We also note that there was some confusion among
      commenters as to our current limitation and proposal of any licensed healthcare professional
      using CPOE to create the first entry of the order into the patient’s medical record as we received
      70
      many comments suggesting that nurses should be able to enter the orders. We clarify that nurses
      who are licensed and can enter orders into the medical record per state, local and professional
      guidelines may enter the order into CEHRT and have it count as CPOE.
      Response: As we did not revise our description of when in the ordering process the
      CPOE function must be used, we are inclined to not revise our description of who may enter it
      into CEHRT. However, we are particularly concerned with CPOE usage by EPs in this regard.
      Many EPs practice without the assistance of other licensed healthcare professionals. These EPs in their comments urged the expansion indicated in the third possibility of credentialed
      healthcare professionals/medical assistants. We believe that this expansion is warranted and protects the concept that the CDS interventions will be presented to someone with medical knowledge as opposed to a layperson. The concept of credentialed healthcare professionals is over broad and could include an untold number of people with varying qualifications. Therefore, we finalize the more limited description of including credentialed medical assistants. The credentialing would have to be obtained from an organization other than the employing organization. Our responses to earlier comments factored into this decision as well. Based onthe public comments received, questions submitted by the public on Stage 1 and demonstrations
      of CEHRT we have participated in, it is apparent that the prevalent time when CDS interventions
      are presented is when the order is entered into CEHRT, and that not all EHRs also present CDS
      when the order is authorized (assuming such a multiple step ordering process is in place). This
      means that the person entering the order could be required to enter the order correctly, evaluate
      CDS either using their own judgment or through accurate relay of the information to the ordering
      provider, and then either make a change to the order based on the CDS intervention or bypass the
      intervention. We do not believe that a layperson is qualified to do this, and as there is no
      71
      licensing or credentialing of scribes, there is no guarantee of their qualifications.

      The language on page 294 is one of the technical corrections that I mention in my article. Note the following from my article:

      Some pages of the 672-page Stage 2 final rule do not contain the “credentialed medical assistants” language from pages 69 to 71, but contain the superseded, Stage 1 language of “licensed healthcare professionals.” These discrepancies should be eliminated in a technical correction rule from CMS—a common procedure for regulations of this length and complexity.

      I hope this is helpful.

      Donald A. Balasa, JD, MBA
      Executive Director, Legal Counsel

      American Association of Medical Assistants
      Ph: 800/228-2262 | Fax: 312/899-1259 | http://www.aama-ntl.org

      Visit us on Facebook! http://www.aama-ntl.org/facebook

      The CMA (AAMA): Health Care’s Most Versatile Professional

  15. Todd lasher,CMA says:

    Hi Don,
    Great job much thanks….you the best

  16. Kathy Edwards, CMA (AAMA) says:

    With this GREAT news (Thank-you by the way) can you help me out as to how to get the news out to the officials law makers (eg legislators, medical society) I am in hope that it will help out in the job market in our state and make aware of the importance to have qualified medical assistants in the office

    • You are welcome, Kathy, and thank you!

      You can use the article that was distributed in connection with my presentation in Scottsdale. I will send to your e-mail a version that does not have the line numbering. You can also direct decision makers to my blog.

      We will also be putting together a one-page summary that should be well suited to the type of distribution you are pursuing.

      I hope this is helpful, Kathy. We will continue to defend the medical assistant’s right to practice in every way we can!

      Don

      Donald A. Balasa, JD, MBA
      Executive Director, Legal Counsel

      American Association of Medical Assistants
      Ph: 800/228-2262 | Fax: 312/899-1259 | http://www.aama-ntl.org

      Visit us on Facebook! http://www.aama-ntl.org/facebook

      The CMA (AAMA): Health Care’s Most Versatile Professional

  17. Marylene Rhyne CMA (AAMA) says:

    I love this website.

  18. BarbaraJo O'Connor Caisse RMA and associate member of AAMA says:

    Hi Don, I am a certified RMA with an AAS in medical assisting and have been working in the profession of medical assistant for 16 years now. I am also a new member of the AAMA having only recently learned that they allow RMAs to hold assoc. membership with the AAMA as well. I love this website it is very helpful to me. Although the RMA and CMA are unfortunately seperated by two different certifying groups, we are both professional medical assistants who went to accredited schools for our degrees and passed rigid certifying exams and we both have to stay current through required CEUs. Wether an RMA or a CMA we are both proud of what we do each day for our patients and proud of the education we have and the credentials we hold which shows the high standard of our learning and our professionalism in our chosen field. I am hopeful that someday both groups can come together for the sake of our profession and we will finally be one group of proud certified medical assistants instead of two sometimes battling groups. Sorry, had to get that out there. We will be a stronger force to reckon with when we are one first…anyway.
    My question to you is this. I currently work for specialist in Connecticut. I work in a practice owned by a mid sized hospital. This organization does not routinely hire certified medical assistants in fact most of the Medical Assistants they hire are not trained at all. They get trained “on the job”. I was surprised to learn this as I didn’t know you could even do that any more. I was hired by the doctor I work for because he had insisted they hire him a certified medical assistant. The office we share a suite in has 3 internal medicine doctors who have a combined 6 medical assistants working for them. Only 3 of those MAs went to school for medical assisting and only 1 of them went on to get her certification. There is also 1 LPN with us since in CT MAs cannot administer medications or injections, among other things we are not allowed to do here. Our practices are all EMR now and we all enter medications and orders into the system as directed by the providers we work for. We all have EMR privelages to e-scribe a refill or change an order as directed by our provider, under the nurse template. So…this new ruling means that only myself and the other RMA in my office are allowed to do this? Bigger picture, it means none of these non schooled or the non certified MAs should be doing any of this now, right? The hospital is really pushing meaningful use and getting the credit for everything they can get it for. This is such a BIG win for us MAs who work with a majority of on the job trained MAs. In fact the majority of practice managers in this particular organization are on the job trained medical assistants who wear the title “Practice manager/medical assistant” on their badges. So how do I get this word out to the organization? I mean CT is very, very strict concerning what a medical asst can and cannot do so I am thinking they will watch this closely anyway. Is there some informational pamphlet or flyer I can give to someone? In fact who do you recommend that someone or department should be when you are dealing with a larger hospital based group? This would mean more jobs for those un-employed but qualified medical assistants out there, you know? I am the practice manager for my small specialist office. My doc relies on me to keep us current with everything and I really want to make sure we are doing everything correctly so at least he does not get in trouble. Can you give me some advice here?
    Thank you and keep up the great work!
    BarbaraJo, RMA, AAS
    Connecticut

    • Thank you for your e-mail, Barbara Jo, and I am glad you like our website!

      Your words about unity within medical assisting are good. You will be happy to know that the AAMA and the Connecticut Society of Medical Assistants recently submitted a scope of practice request to the Connecticut legislature that would, hopefully, result in medical assistants regaining the right to be delegated certain types of injections. Here are some excerpts from our scope of practice request:

      Request: The Connecticut Society of Medical Assistants and the American Association of Medical Assistants request that the Connecticut General Assembly enact legislation that would enable licensed physicians to delegate:
      (1) the administration of medication orally or by inhalation; and
      (2) the administration of intramuscular, intradermal, and subcutaneous injections (including vaccinations/immunizations)
      to medical assistants working under their direct supervision (as defined above) in outpatient settings who:
      (1) have graduated from an accredited, postsecondary medical assisting program that is accredited by either the Commission on Accreditation of Allied Health Education Programs (CAAHEP) or the Accredited Bureau of Health Education Schools (ABHES)—the only academic accrediting bodies that are recognized by either the United States Department of Education or the Council for High Education Accreditation; and
      (2) have a current medical assisting credential acceptable to, and recognized by, the Connecticut Medical Examining Board and the Connecticut Department of Public Health.

      (B) Potential public health and safety benefits, and potential harm to public health and safety, should the request not be implemented

      If a law described immediately above were enacted, the people of Connecticut would benefit by having greater access to, and availability of, health care. Under current law, physicians are restricted in the categories of allied health professionals to whom they may delegate medication administration. Allowing physicians to delegate certain types of medication administration to educated and credentialed medical assistants would increase the supply of allied health professionals, and consequently the efficiency of the provision of health care. This would enable physicians to see a greater number of patients in a shorter time, without any diminishment of the quality of care provided to patients.

      If the above request for legislation were not granted, the Connecticut health system, delegating physicians, and patients would be deprived of the efficiencies of fully utilizing competent and knowledgeable medical assistants. In other words, the availability of health care involving certain types of medication administration would be less than it would be if educated and credentialed medical assistants were able to use their full range of abilities under direct physician supervision.

      AMT is fully supportive of this effort. AAMA and AMT should be able to work together on this important effort in your state.

      The CMS final rule does mean that only credentialed medical assistants are permitted to enter orders into the electronic health record in order for this to count as meaningful use under the Medicare and Medicaid incentive program. I will e-mail you a flyer we put together about this.

      I hope this is helpful, Barbara Jo. I will send that flyer to you right away.

      Don

      Donald A. Balasa, JD, MBA
      Executive Director, Legal Counsel

      American Association of Medical Assistants
      Ph: 800/228-2262 | Fax: 312/899-1259 | http://www.aama-ntl.org

      Visit us on Facebook! http://www.aama-ntl.org/facebook

      The CMA (AAMA): Health Care’s Most Versatile Professional

      • Meagan Blackington CMA (AAMA) says:

        Great strides for our profession! I too, work with non-credentialed and on-the-job trained medical assistants in Las Vegas, Nv. In the interest of patient care as well as ensuring guidelines and laws are followed, I have been looking for and not finding, any information about what the MINIMUM requirements are to work as an MA in this state. Is there a grandfathering of non educated MAs? What is the impact on meaningful use incentives if said employees are entering orders and prescriptions? Even if the practice owner is ok with it? I appreciate your help and the work you do for us!

      • Thank you for your questions and comments, and for your kind words!

        There are no minimum requirements for medical assistants under Nevada law. When the Nevada Board of Medical Examiners issues regulations implementing the 2011 law enacted by the NV legislature, there will be more specific provisions on what medical assistants are permitted to do under direct physician supervision.

        If medical assistants who are not credentialed enter orders into the computerized provider order entry system, according to the CMS final rule, these entries cannot be considered meaningful use as defined under the Medicare and Medicare Incentive Program for Electronic Medical Records.

        I hope this is helpful. Please let me know whether you have additional questions.

        Donald A. Balasa, JD, MBA
        Executive Director, Legal Counsel

        American Association of Medical Assistants
        Ph: 800/228-2262 | Fax: 312/899-1259 | http://www.aama-ntl.org

        Visit us on Facebook! http://www.aama-ntl.org/facebook

        The CMA (AAMA): Health Care’s Most Versatile Professional

      • BarbaraJo O'Connor Caisse RMA and associate member of AAMA says:

        Thank you Don for giving me the great info about the AAMA’s legal effort in CT to get our scope of practice broadened here. The college I graduated from (class of 97′) was in Maine so I was trained on how to do injections. I worked as an MA in Maine until 2002 at which time I got married and we moved down to my husband’s home state of CT. Imagine my surprise when the hospital based out patient clinc I was working for gave me a verbal warning for following a physcian’s direction and giving a patient a Tetanus booster. One of the other MAs in the practice called the nursing division at the hospital and reported me and the physican. I was sat down and talked to and only when it was learned I was trained in Maine and that this was my first medical assistant position in the state of CT did the written warning turn into a verbal one. I was told we will assume you were not told the rules for medical assistants are different in CT. The doctor, however, did get in trouble “for taking advantage of the fact that I was experienced in giving injections but did not know I could not do that in CT. The head of the nursing department said to me that they had to write me up and discipline the doctor because if someone reported to the state that I was giving shots they could be fined. So that was my rather rude introduction to medical assisting in the state of CT. I am hopeful this ruling the AAMA has put forth will at least get them to think and hopefully they will change it to something more in line with most other states. Thank you for all you are doing for medical assistants and for this wonderful blog. BTW I showed the info on the CMS ruling to the doctor I work for and reminded him that of course he is fine because I am certified but most of the other MAs in the office are in house trained so what about their doctors? He said that what the hospital we work for will most likely do is just put that work all back on the doctors themselves or the one LPN in the office. He said the hospital would never be able to afford to hire or justify hiring certified medical assistants when they can continue to use un-certified ones or train their own for everything else they already do anyway. He said the only reason I was hired was because when they hired him, who came from working at Yale, he said he would not his practice w/o a certified and experienced medical assistant. So since they really wanted him they said okay you can have a certified med asst. Interesting, huh.

      • You are welcome, Barbara Jo! I am glad you found the information helpful. Your story about your experience in Connecticut is quite something!

        We already see an increasing number of employers who prefer to, or even insist on, hiring CMAs (AAMA). Of course, there are still many employers who do not. However, with legislative victories in Nevada and Washington within the past few years, and with a great opportunity in Connecticut, and with this CMS final rule, we are gathering some momentum.

        Thank you again, Barbara Jo. I will seek to keep everyone informed of important issues for the medical assisting profession.

        Don

        Donald A. Balasa, JD, MBA
        Executive Director, Legal Counsel

        American Association of Medical Assistants
        Ph: 800/228-2262 | Fax: 312/899-1259 | http://www.aama-ntl.org

        Visit us on Facebook! http://www.aama-ntl.org/facebook

        The CMA (AAMA): Health Care’s Most Versatile Professional

  19. networkjd says:

    Thanks. I would like to add this information to the general information I have on online medical assistant programs for others to see.

    • Thanks for reading, networkjd! We’d be happy to allow you to use AAMA information. However, we ask that you provide a link to attribute the Legal Eye on Medical Assisting blog:

      Medical Assistants Win Big in CMS Ruling
      AAMA Legal Eye On Medical Assisting

      Or you can quote the information and provide this statement:

      Reprinted with permission from the American Association of Medical Assistants as presented in the blog Legal Eye On Medical Assisting, written by AAMA Executive Director and Legal Counsel Donald A. Balasa, JD, MBA.

      I hope this is helpful. Please let me know if you have additional questions.

      Donald A. Balasa, JD, MBA
      Executive Director, Legal Counsel

      American Association of Medical Assistants
      Ph: 800/228-2262 | Fax: 312/899-1259 | http://www.aama-ntl.org

      Visit us on Facebook! http://www.aama-ntl.org/facebook

      The CMA (AAMA): Health Care’s Most Versatile Professional

  20. Melissa Burbage CMA (AAMA) says:

    Good Morning Mr. Balasa,
    I am the owner of a large pedaitric office and honored to have the state VP medical assistant work here. She has informed me of these possible changes with order entry. We have a few NON CERTIFIED medical assistants that do ‘create’ an order within our EHR that is always ‘approved’ by the doctor however they ‘click’ the order button within the note. These are all in-house labs (clia-waived). This is also the case with rx in our medical records. They will ‘create’ the rx and we will either erx it (the doctors) or hand write it. The MA’s in our office do not order tests/rx medications that are not approved by the doctors BEFOREHAND. How does this ruling effect us? Will our NON CERTIFIED medical assistants still be able to do this?
    Thank you for your time, Colleen Boylston, MD Sweetgrass Pediatrics

    • Thank you for your question, Dr. Boylston. I am most happy to be of assistance to you and Melissa Burbage, CMA (AAMA), who is indeed an outstanding AAMA leader!

      It is my legal opinion that, for purposes of being considered meaningful use for the Medicare and Medicaid Electronic Health Record Incentive Program, non-credentialed medical assistants will not be permitted to enter the orders you describe below, even though you and your fellow physicians approve the orders before they are entered into the EHR. It is permissible, however, for non-credentialed medical assistants to enter orders for non-meaningful use purposes.

      I hope this is helpful, Dr. Boylston. Please let me know whether you like further clarification, or whether you have additional questions.

      Donald A. Balasa, JD, MBA
      Executive Director, Legal Counsel

      American Association of Medical Assistants
      Ph: 800/228-2262 | Fax: 312/899-1259 | http://www.aama-ntl.org

      Visit us on Facebook! http://www.aama-ntl.org/facebook

      The CMA (AAMA): Health Care’s Most Versatile Professional

  21. Debra Pogwizd says:

    Mr. Balasa,
    Can a Registered or Certified MA in the state of IL start and IV? Give injectible or oral medications? Administer vaccines? All and any of which need to count toward Meaningful Use. Please advise. This is a huge question here for us.

  22. Traci SuSong says:

    Bravo!!
    Will the Ohio Administrative Code include this information (order entry) as my employer will use the State’s law to identify what the MA can and can’t do

    • Thank you for your question. I am happy to respond.

      I will send to your e-mail address the Ohio medical assisting law. I do not think that the laws of any states will be changed to reflect this CMS final rule. However, I find nothing in the Ohio law and the laws of all other states that forbids physicians from delegating to competent and knowledgeable medical assistants working under their direct supervision in outpatient settings the entry of orders into the electronic health record.

      I hope this is helpful.

      Donald A. Balasa, JD, MBA
      Executive Director, Legal Counsel

      American Association of Medical Assistants
      Ph: 800/228-2262 | Fax: 312/899-1259 | http://www.aama-ntl.org

      Visit us on Facebook! http://www.aama-ntl.org/facebook

      The CMA (AAMA): Health Care’s Most Versatile Professional

  23. A Medical Assistant (MA) is an integral member of the health care delivery team, qualified
    by education and experience to work in the administrative office, the examining room and the
    physician office laboratory. The Medical Assistant, also a liaison between the doctor and the
    patient, is of vital importance to the success of the medical practice.Nature of the Work
    Thandiwe.

  24. karim ahmed says:

    Everyone should contribute in medical science. Medical assistant is an asset for every patient.
    Want to more click on skin care

  25. Mariruth Johnson says:

    I have a question…is a MA which recieved a NCCT (national center for competency) certification able to enter medications under this new CMS rule?

  26. S. Turner says:

    Thank you for being active in defending and promoting the Medical Assisting profession and the respect thereof. I believe these accomplishments will benefit greatly, CMA’s who find it difficult to find employment because of in-house trained medical assistants and/or employers hiring persons simply because they know them.

    If you will, please answer the following questions?

    1. How would you advise a newly and/or recent certified medical assistant to obtain employment?
    2. For those certified medical assistants who volunteer to gain experience and employment, yet still find it difficult to become hired – what would you suggest?

    I ask the above questions because I am aware of certified medical assistants who have not found employment in their profession after diligently seeking for 2-3 years.

    Thank you for your time and consideration.

    • You are welcome and thank you. I and one of my staff colleagues will respond directly to your email.

      Sent from my iPhone

    • Anna Johnson says:

      I am sorry to hear that you are experiencing difficulty in finding a medical assisting position. Here are a few suggestions to consider:

      * As a suggestion for seeking employment, you might want to start by seeking Administrative positions. If you have been seeking employment in hospitals or nursing homes, it would be helpful to try seeking employment in clinics or medical offices. Make the focus of your job search on out-patient settings rather than in-patient settings. * If you are a CMA (AAMA) and are a member of the AAMA you will be on the mailing list for any job opportunities if we are contacted by an employer that wants to do a mailing in their area. * You might wish to attend your local chapter meetings and talk with your colleagues about their job search if possible. Also, many jobs within the medical community are never advertised and you may only hear about them unless you are plugged into the community healthcare network.

      * Talk to your medical assisting program placement department and/or the director of your program. Some programs offer lifetime placement assistance to their graduates.

      * If there is a medical placement agency or temp agency in your area, give your resume to them.

      * Sometimes the county medical society office is a resource for the medical offices in your area. They may keep a file of resumes there.

      I hope this is at least somewhat helpful and I wish you success in your efforts.

      Sincerely,

      Anna Johnson

  27. Megan Burdick says:

    Good morning,

    I am currently working at a large FQHC based in Michigan and and have 30+ Medical Assistants. Roughly 7 of those MA’s are certified. I have just a few questions if you could answer them for me.

    For my Medical Assistants who are currently certified, they need to have 60 CEU’s within their 5 year time period to stay active, correct?

    For my Medial Assistants who were previously certified, but have now passed their 5 years…they need sit again for the test?

    For my Medical Assistants who have never been certified (either career school students or those who have been on the job trained)…they can go through the the RMA testing?

    Thank you so much for your time,

    Megan Burdick, CMA

    • Thank you for your questions. I will answer some of them, and my colleague Anna Johnson, Associate Executive Director and Director of Certification, will provide more detailed answers.

      CMAs (AAMA) are required to recertify every 60 months in order to keep the CMA (AAMA) current and to be able to use it. CMAs (AAMA) are permitted to recertify by examination or by continuing education. Ms. Johnson will provide details about recertification.

      The policy of the Certifying Board of the AAMA is that individuals whose CMA (AAMA) has not been current for more than 60 months are required to retest in order to recertify. Once again, Ms. Johnson will provide specifics.

      I will forward to your e-mail my CMA Today article entitled “How the CMA (AAMA) Stands Apart: A Comparison of Four Medical Assisting Certifications.”

      Thank you again for your questions.

      Donald A. Balasa, JD, MBA
      Executive Director, Legal Counsel

      American Association of Medical Assistants
      Ph: 800/228-2262 | Fax: 312/899-1259 | http://www.aama-ntl.org

      Visit us on Facebook! http://www.aama-ntl.org/facebook

      The CMA (AAMA): Health Care’s Most Versatile Professional

  28. Liz Hoffman says:

    Don,

    On behalf of medical assistants nationwide, THANK YOU for your efforts and success! ☺

    Liz Hoffman, MA Ed, CMA, (AAMA), CPT, (ASPT)
    Associate Dean of Health Science
    Baker College Clinton Township Michigan

  29. Megan Burdick says:

    Is this ruling only for Meaningful Use dollars under Medicare or does it apply to Medicaid also? (We are going for Meaningful Use dollars under Medicaid)

    Does this ruling apply to Medicare Billing in EHR?

    Thank you again,
    Megan Burdick, CMA

  30. jennifer says:

    Does this new ruling allow for a CMA in south Carolina to send electronic prescriptions if delegated by a physician

  31. Dianne Stevens says:

    Hi Attorney Balasa: I manage a medical group in CT and am following up on the Scope of Practice Request for MAs submitted to the CT legislature sometime in August/September 2012. I gather that either the legislature did not act on the Request? Can you provide some follow-up please?

    • Thank you for your question. Here is an update:

      Connecticut

      On February 1, 2013, the Connecticut Department of Public Health issued a favorable report to the Connecticut General Assembly in regard to the scope of practice request submitted by the Connecticut Society of Medical Assistants and the AAMA. Holly Martin, CMA (AAMA), and Wendy Carros, CMA (AAMA) of the Connecticut Society are to be commended for their excellent leadership and hard work throughout the scope of practice request process. This is an important precedent that should have a positive impact on right to practice efforts in other states.

      Unfortunately, legislation embodying the scope of practice request was not introduced into the Connecticut General Assembly. However, the Connecticut Society will now have the opportunity to work with all parties that were involved in the scope of practice request process to craft legislative language that is acceptable to all parties. A bill can then be raised during the next session of the Connecticut legislature.

      I hope this is helpful.

      Donald A. Balasa, JD, MBA
      Executive Director, Legal Counsel

      American Association of Medical Assistants
      Ph: 800/228-2262 | Fax: 312/899-1259 | http://www.aama-ntl.org

      Visit us on Facebook! http://www.aama-ntl.org/facebook

      The CMA (AAMA): Health Care’s Most Versatile Professional

  32. Cindy Gordon says:

    I received a call from a local employer asking if a person who sat and passed the NRCMA exam met the requirements as a credentialed MA. Can you please comment on this.

    • Thank you for your question.

      The definition of “credentialed medical assistant” in the CMS rule is broad. Note the following Q & A from CMS:

      Q: In order to meet the objective for computerized order entry (CPOE) for the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs, do medical assistants need a specific kind of credential from a specific organization to be considered credentialed and therefore able to enter orders using CPOE that can count in the numerator of the measure?

      A: A credentialed medical assistant is a medical assistant who has received credentials or otherwise been certified by an organization other than the employing organization to perform duties as a medical assistant. CMS does not specify credentialing organizations that would qualify medical assistants under this definition. Medical assistants who are credentialed, certified, licensed, or otherwise affirmed as medical assistants by an organization other than the one which employees them can enter orders for the purpose of this objective.

      Also, please note the following from my article from the November-December 2012 CMA Today:

      Limitations in identifying
      specific credentials
      A question has been raised about
      why the Centers for Medicare and
      Medicaid Services (CMS) did not limit
      its recognition of medical assistants
      to those with a current CMA (AAMA)
      credential. The answer is that regulation
      of professions rests primarily
      with the states. This time-honored
      legal principle is rooted in the “police
      power” reserved to the states by
      the Tenth Amendment of the United
      States Constitution. The police power
      consists of the authority of each state
      to safeguard the health, safety, and
      welfare of its citizens by legislation,
      executive branch regulations, and
      the enforcement of these provisions.
      The CMS, therefore, has very limited
      authority to determine which medical
      assisting credentials are sufficient
      to protect the public. The CMS can
      only establish broad parameters in
      regard to which professionals should
      be authorized to carry out certain
      functions under the Medicare and
      Medicaid Electronic Health Record
      Incentive Program.

      Therefore, the answer to your question is that the NRCMA exam would fall into the definition of “credentialed medical assistant” in the CMS rule.

      I hope this is helpful. Please let us know how we can be of further assistance.

      Donald A. Balasa, JD, MBA
      Executive Director, Legal Counsel

      American Association of Medical Assistants
      Ph: 800/228-2262 | Fax: 312/899-1259 | http://www.aama-ntl.org

      Visit us on Facebook! http://www.aama-ntl.org/facebook

      The CMA (AAMA): Health Care’s Most Versatile Professional

  33. Shannan says:

    I’m a surgical tech who works in an office in a MA role. Can my certification be used or do I have to be a CMA?

  34. I am trying to find the official rule in the Federal Register. Can you tell me what page or pages it is on? I have looked through all of the questions and answers above, but I’m not finding it on pages 69-71. Thanks!

    • Thank you for your question. Here is the first page of the rule in the Federal Register:

      53968 Federal Register / Vol. 77, No. 171 / Tuesday, September 4, 2012 / Rules and Regulations
      DEPARTMENT OF HEALTH AND
      HUMAN SERVICES
      Centers for Medicare & Medicaid
      Services
      42 CFR Parts 412, 413, and 495
      [CMS–0044–F]
      RIN 0938–AQ84
      Medicare and Medicaid Programs;
      Electronic Health Record Incentive
      Program—Stage 2
      AGENCY: Centers for Medicare &
      Medicaid Services (CMS), HHS.
      ACTION: Final rule.
      SUMMARY: This final rule specifies the
      Stage 2 criteria that eligible
      professionals (EPs), eligible hospitals,
      and critical access hospitals (CAHs)
      must meet in order to qualify for
      Medicare and/or Medicaid electronic
      health record (EHR) incentive payments.
      In addition, it specifies payment
      adjustments under Medicare for covered
      professional services and hospital
      services provided by EPs, eligible
      hospitals, and CAHs failing to
      demonstrate meaningful use of certified
      EHR technology (CEHRT) and other
      program participation requirements.
      This final rule revises certain Stage 1
      criteria, as finalized in the July 28, 2010
      final rule, as well as criteria that apply
      regardless of Stage.
      DATES: Effective dates: This final rule is
      effective on November 5, 2012, with the
      exception of the definition of
      ‘‘meaningful EHR user’’ in § 495.4 and
      the provisions in § 495.6(f), § 495.6(g),
      § 495.8, § 495.102(c), and part 495
      subpart D, which are effective
      September 4, 2012.
      Applicability dates: Sections 495.302,
      495.304, and 495.306 are applicable
      beginning payment year 2013.
      FOR FURTHER INFORMATION CONTACT:
      Elizabeth Holland, (410) 786–1309, or
      Robert Anthony, (410) 786–6183, EHR
      Incentive Program issues or
      Administrative appeals process issues.
      David Koppel, (410) 786–3255, for
      Medicaid Incentive Program issues.
      Frank Szeflinski, (303) 844–7119, for
      Medicare Advantage issues. Travis
      Broome, (214) 767–4450, Medicare
      payment adjustment issues. Douglas
      Brown, (410) 786–0028, or Maria
      Michaels, (410) 786–2809 for Clinical
      quality measures issues.
      SUPPLEMENTARY INFORMATION:
      Acronyms
      ARRA American Recovery and
      Reinvestment Act of 2009
      AAC Average Allowable Cost (of CEHRT)
      ACO Accountable Care Organization
      AIU Adopt, Implement, Upgrade (CEHRT)
      CAH Critical Access Hospital
      CAHPS Consumer Assessment of
      Healthcare Providers and Systems
      CCN CMS Certification Number
      CDS Clinical Decision Support
      CEHRT Certified Electronic Health Record
      Technology
      CFR Code of Federal Regulations
      CHIP Children’s Health Insurance Program
      CHIPRA Children’s Health Insurance
      Program Reauthorization Act of 2009
      CMS Centers for Medicare & Medicaid
      Services
      CPOE Computerized Provider Order Entry
      CQM Clinical Quality Measure
      CY Calendar Year
      EHR Electronic Health Record
      EP Eligible Professional
      EPO Exclusive Provider Organization
      FACA Federal Advisory Committee Act
      FFP Federal Financial Participation
      FFY Federal Fiscal Year
      FFS Fee-For-Service
      FQHC Federally Qualified Health Center
      FTE Full-Time Equivalent
      FY Fiscal Year
      HEDIS Healthcare Effectiveness Data and
      Information Set
      HHS Department of Health and Human
      Services
      HIE Health Information Exchange
      HIT Health Information Technology
      HITPC Health Information Technology
      Policy Committee
      HIPAA Health Insurance Portability and
      Accountability Act of 1996
      HITECH Health Information Technology for
      Economic and Clinical Health Act
      HMO Health Maintenance Organization
      HOS Health Outcomes Survey
      HPSA Health Professional Shortage Area
      HRSA Health Resource and Services
      Administration
      IAPD Implementation Advance Planning
      Document
      ICR Information Collection Requirement
      IHS Indian Health Service
      IPA Independent Practice Association
      IT Information Technology
      LOINC Logical Observation Identifiers and
      Codes System
      MA Medicare Advantage
      MAC Medicare Administrative Contractor
      MAO Medicare Advantage Organization
      MCO Managed Care Organization
      MITA Medicaid Information Technology
      Architecture
      MMIS Medicaid Management Information
      Systems
      MSA Medical Savings Account
      NAAC Net Average Allowable Cost (of
      CEHRT)
      NCQA National Committee for Quality
      Assurance
      NCVHS National Committee on Vital and
      Health Statistics
      NPI National Provider Identifier
      NPRM Notice of Proposed Rulemaking
      ONC Office of the National Coordinator for
      Health Information Technology
      PAHP Prepaid Ambulatory Health Plan
      PAPD Planning Advance Planning
      Document
      PCP Primary Care Provider
      PECOS Provider Enrollment, Chain, and
      Ownership System
      PFFS Private Fee-For-Service
      PHO Physician Hospital Organization
      PHR Personal Health Record
      PHS Public Health Service
      PHSA Public Health Service Act
      PIHP Prepaid Inpatient Health Plan
      POS Place of Service
      PPO Preferred Provider Organization
      PQRS Physician Quality Reporting System
      PSO Provider Sponsored Organization
      RHC Rural Health Clinic
      RPPO Regional Preferred Provider
      Organization
      SAMHSA Substance Abuse and Mental
      Health Services Administration
      SMHP State Medicaid Health Information
      Technology Plan
      TIN Tax Identification Number
      Table of Contents
      I. Executive Summary and Overview
      A. Executive Summary
      1. Purpose of Regulatory Action
      a. Need for the Regulatory Action
      b. Legal Authority for the Regulatory
      Action
      2. Summary of Major Provisions
      a. Stage 2 Meaningful Use Objectives and
      Measures
      b. Reporting on Clinical Quality Measures
      (CQMs)
      c. Payment Adjustments and Exceptions
      d. Modifications to Medicaid EHR
      Incentive Program
      e. Stage 2 Timeline Delay
      3. Summary of Costs and Benefits
      B. Overview of the HITECH Programs
      Created by the American Recovery and
      Reinvestment Act of 2009
      II. Provisions of the Proposed Regulations
      and Analysis of and Responses to Public
      Comments
      A. Definitions Across the Medicare FFS,
      Medicare Advantage, and Medicaid
      Programs
      1. Uniform Definitions
      2. Meaningful EHR User
      3. Definition of Meaningful Use
      a. Considerations in Defining Meaningful
      Use
      b. Changes to Stage 1 Criteria for
      Meaningful Use
      c. State Flexibility for Stage 2 of
      Meaningful Use
      d. Stage 2 Criteria for Meaningful Use (Core
      Set and Menu Set)
      (1) Discussion of Whether Certain EPs,
      Eligible Hospitals or CAHs can meet all
      Stage 2 Meaningful Use Objectives Given
      Established Scopes of Practice
      (2) EPs Practicing in Multiple Practices/
      Locations
      (3) Discussion of the Reporting
      Requirements of the Measures
      Associated with the Stage 2 Meaningful
      Use Objectives
      B. Reporting on Clinical Quality Measures
      Using Certified EHRs Technology by
      Eligible Professionals, Eligible Hospitals,
      and Critical Access Hospitals
      1. Time Periods for Reporting Clinical
      Quality Measures
      2. Certification Requirements

      Donald A. Balasa, JD, MBA
      Executive Director, Legal Counsel

      American Association of Medical Assistants
      Ph: 800/228-2262  |  Fax: 312/899-1259  |  http://www.aama-ntl.org

      Visit us on Facebook! http://www.aama-ntl.org/facebook  

      The CMA (AAMA): Health Care’s Most Versatile Professional

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