During the coverage of the Centers for Medicare and Medicaid Services (CMS) Stage 2 rule, there was some thought that CMS auditors would not have the authority to inquire about the credential status of medical assistants entering orders into the computerized provider order entry (CPOE) system.
This thinking is incorrect. To qualify for payments under the Electronic Health Records (EHR) Incentive Programs, providers will be required to present documentation of all entries, many of which are automatically kept by the EHR system. CMS auditors do have the authority to determine whether entry of medication, laboratory, and radiology orders has been made by licensed health care professionals or credentialed medical assistants. If it is discovered that order entry was done by individuals other than licensed professionals or credentialed medical assistants, the auditors could cite this violation, and it is possible that the order entry by these individuals would not be counted toward meeting the meaningful use thresholds. As a result, the eligible professional may not meet all the core objectives and consequently would not receive incentive payments.
The reality of these audits only serves to emphasize the importance of employing credentialed employees in the health care setting. A description of the CMS EHR audit process can be found in the attached document. In addition, I have provided a link to a question and answer session I took part in with Robert Anthony of CMS.
CMS EHR Incentive Programs Audits
The CMS Rule for Meaningful Use Order Entry, Question and Answer Session
Following my last post, I received a question about medical assistants in the state of Washington who may have been “grandfathered” into the Washington MA-C credential, and thus have never passed a national certification exam. Would such medical assistants be considered properly “credentialed” by the Centers for Medicare and Medicaid Services (CMS) for entering orders into the computerized provider order entry system for meaningful use purposes under the Medicare and Medicaid Incentive Programs?
It is my opinion that, under Washington law, Medical Assistants-Certified (MA-Cs) who were grandfathered in because they were previously Health Care Assistants (HCAs) would not be considered “credentialed medical assistants” under the CMS Incentive Programs rule. Likewise, Medical Assistants-Registered (MA-Rs) would not be considered credentialed, because they did not take and pass an examination given by a third-party credentialing body.
In addition, the question also raised concern that many medical assistants would only earn a credential to satisfy the initial CMS requirement, and not keep that credential current. Remember, any medical assistant whose CMA (AAMA) credential is not current cannot use the credential for any purposes, including order entry. A CMA (AAMA) who is not current, therefore, would not be considered “credentialed” under the CMS rule.
On September 29th, I gave a joint presentation with Robert Anthony, deputy director of the Health Information Technology Initiatives Group of the Centers for Medicare and Medicaid Services (CMS) to the House of Delegates at the AAMA 57th Annual Conference in Atlanta. The presentation dealt with the CMS rule for meaningful use order entry. Deputy Director Anthony affirmed some key points I had presented in previous articles and speeches, and provided an overview of the Medicare and Medicaid Electronic Health Records (EHR) Incentive Programs. He was also kind enough to provide his presentation for your viewing. His presentation and mine are available below, as well as a summary of the key points, as written for the upcoming November/December 2013 issue of CMA Today.
The CMS Rule for Meaningful Use Order Entry
Medicare and Medicaid EHR Incentive Programs
CMS official affirms AAMA positions on meaningful use
Since my post dealing with scope of practice issues under nurse practitioners and physician assistants, I have received a number of questions asking for clarification, particularly regarding the separate medical assisting credentials in Washington State.
Below are the documents outlining the credentialing requirements for two of the medical assistant categories (Registered and Phlebotomist) from the Washington State Department of Health. The credentialing requirements for the “Certified or Interim” category of medical assistants will appear in a follow-up post.
I hope these documents prove useful in answering your queries, but as usual, please contact me with any additional questions or concerns.
It had been brought to my attention that the standard electronic health record (EHR) software product of Epic Systems Corporation did not permit medical assistants to enter orders into it unless the software was specially customized.
Yesterday I spoke with Stirling Martin, senior vice president of Epic. He informed me that Epic’s EHR product allows users to configure the authorizations to enter data as they think best. Mr. Martin assured me that Epic’s software permits medical assistants to enter orders into it if the user authorizations are set up properly.
Please contact me if you have any questions.