Recently I received the following first-time question:
Is it illegal for a medical assistant to also function as the physician’s scribe? The office manager told me that a new law states that a medical assistant either can function as a scribe or as a medical assistant, but cannot assume both roles.
I am not aware of any state or federal laws that forbid a medical assistant from also functioning as the physician’s scribe. Medical assistants who have graduated from a CAAHEP or ABHES accredited medical assisting program and who hold a current CMA (AAMA) credential should be knowledgeable in scribing for the physician or other provider.
I have received questions to the following effect: “Which medical assisting academic programs are ‘CMA (AAMA) programs,’ and which are ‘RMA(AMT) programs’?”
This is an imprecise way to frame the question. It is better to ask what the eligibility pathways are for the CMA (AAMA) Certification Examination, and for the RMA(AMT) Examination.
Applicants for the CMA (AAMA) Certification Examination for initial certification must be graduates of CAAHEP (Commission on Accreditation of Allied Health Education Programs) or ABHES (Accrediting Bureau of Health Education Schools) accredited medical assisting programs, and must meet the other requirements established by the Certifying Board of the AAMA. (Information regarding such programs can be found on the AAMA website.)
There are five eligibility routes for the RMA(AMT) Examination. One of the five is the education route. Note the following from the website of AMT:
Graduated from an accredited MA program (ROUTE 1–Education)
- Training programs must be accredited by an agency approved by the DOE
- Training programs must have 720 clock hours of instruction, including at least 160 clock hours of externship
- If graduated more than 4 years ago, must also have 3 out of the last 5 years of work experience as an MA in both clinical and administrative areas
Consequently, in addition to graduates of CAAHEP and ABHES accredited medical assisting programs, graduates of medical assisting programs in schools that are accredited by an accrediting body recognized by the United States Department of Education (DOE), and that have the required clock hours of instruction and externship specified above, are eligible for the RMA(AMT) Examination.
As part of its Work Plan for Fiscal Year 2015, the Office of Inspector General (OIG) of the Department of Health and Human Services is initiating an audit program of the Medicare Electronic Health Record (EHR) Incentive Program. This audit program will be conducted in addition those already being performed by Figliozzi and Company, the audit contractor for the Centers for Medicare and Medicaid Services.
Any eligible professionals (EPs) who received incentive payments from Jan. 1, 2011, to June 30, 2014, are eligible to be randomly selected for auditing. The OIG will review certain meaningful use measures to determine whether selected EPs incorrectly received any incentive payments, and whether those EPs have adequately protected patients’ health information created or maintained by the EHR. As part of the auditing process, the agency will request specific information and documentation of compliance with the meaningful use measures under review.
To prepare for the possibility of an audit, all EPs should review their documentation for each meaningful use measure and for every year an incentive payment was received. For more information, visit the CMS meaningful use meaningful use audits webpage and access the Medical Group Management Association’s Meaningful Use Resource Center.
Posted in Computerized Provider Order Entry (CPOE), EHR Incentive Programs, Medicare, On the Job
Tagged Centers for Medicare and Medicaid Services, CMS, EHR, EHR incentive programs, meaningful use, Medicare EHR Incentive Program, Office of Inspector General, OIG
As a follow-up to my post yesterday, the March 20, 2015, Centers for Medicare and Medicaid (CMS) notice of proposed rulemaking (NPRM) for Stage 3 of the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs has expanded the category of radiology orders to include diagnostic imaging other than radiology. Also, the thresholds for medication, laboratory, and diagnostic imaging orders have been increased for Stage 3. Note the following excerpts from the CMS NPRM:
We propose to continue our policy from the Stage 2 final rule that the orders to be included in this objective are medication, laboratory, and radiology orders, as such orders are commonly included in CPOE implementation and offer opportunity to maximize efficiencies for providers. However, for Stage 3, we are proposing to expand the objective to include diagnostic imaging, which is a broader category including other imaging tests such as ultrasound, magnetic resonance, and computed tomography in addition to traditional radiology. This change addresses the needs of specialists and allows for a wider variety of clinical orders relevant to particular specialists to be included for purposes of measurement.
Based on our review of attestation data from Stages 1 and 2 demonstrating provider performance on the CPOE measures, we propose to increase the threshold for medication orders to 80 percent and to increase the threshold for diagnostic imaging orders and laboratory orders to 60 percent.
On March 20, 2015, the Centers for Medicare and Medicaid Services (CMS) issued a notice of proposed rulemaking (NPRM) for Stage 3 of the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs. I am pleased to report that the Proposed Objective for computerized provider order entry (CPOE) in the NPRM is very favorable for credentialed medical assistants such as CMAs (AAMA). Note the following excerpts from the Notice of Proposed Rulemaking:
Proposed Objective: Use computerized provider order entry (CPOE) for medication, laboratory, and diagnostic imaging orders directly entered by any licensed healthcare professional, credentialed medical assistant, or a medical staff member credentialed to and performing the equivalent duties of a credentialed medical assistant; who can enter orders into the medical record per state, local, and professional guidelines.…
In Stage 3, we propose to continue the policy from the Stage 2 final rule at
77 FR 53986 that orders entered by any licensed healthcare professional or credentialed medical assistant would count toward this objective. A credentialed medical assistant may enter orders if they are credentialed to perform the duties of a medical assistant by a credentialing body other than the employer. If a staff member of the eligible provider is appropriately credentialed and performs assistive services similar to a medical assistant, but carries a more specific title due to either specialization of their duties or to the specialty of the medical professional they assist, orders entered by that staff member would be included in this objective. We further note that medical staff whose organizational or job title, or the title of their credential, is other than medical assistant may enter orders if these staff are credentialed to perform the equivalent duties of a credentialed medical assistant by a credentialing body other than their employer and perform such duties as part of their organizational or job title. We defer to the provider’s discretion to determine the appropriateness of the credentialing of staff to ensure that any staff entering orders have the clinical training and knowledge required to enter orders for CPOE.…
However, as stated in the Stage 2 final rule at 77 FR 53986, it is apparent that the prevalent time when CDS [Clinical Decision Support] interventions are presented is when the order is entered into CEHRT [Certified Electronic Health Record Technology], 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 would be required to enter the order correctly, evaluate a CDS intervention 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 information provided by the CDS intervention or bypass the intervention. The execution of this role represents a significant impact on patient safety; therefore, we continue to maintain for Stage 3 that a layperson is not qualified to perform these tasks. [Emphasis added]
The full document can be found here. I will provide further excerpts and summaries later this week and next week.
Posted in Certification and the CMA (AAMA) Credential, Computerized Provider Order Entry (CPOE), EHR Incentive Programs, On the Job, Scope of Practice
Tagged Centers for Medicare and Medicaid Services, certification, certified medical assistant, certified medical assistants, CMA (AAMA), CMA (AAMA) credential, CMS, CMS Rule, CMS rulings, computerized provider order entry