Because most CMAs (AAMA) work under the direct supervision of “eligible professionals” (as defined in the rules of the Centers for Medicare and Medicaid Services [CMS]), this post focuses on some common questions surrounding the provisions of the Medicare and Medicaid Electronic Health Records (EHR) Incentive Program that are applicable to eligible professionals, not those provisions that are applicable to “eligible hospitals” and “critical access hospitals.”
Q: Who can enter orders into the EHR to contribute to the meeting of the Stage 1 and 2 measures for CPOE?
A: Stage 1 of the Incentive Program specified that only “licensed health care professionals” could enter orders into the CPOE system for meaningful use calculation purposes. At the urging of the American Association of Medical Assistants and other parties, on August 23, 2012, CMS issued a final rule allowing “credentialed medical assistants” to enter orders into the CPOE system for the purpose of calculating compliance with this Core Objective. The CMS Stage 2 Eligible Professional Meaningful Use Core Measures document, issued in October of 2012, includes the following statement: “Any licensed healthcare professionals and credentialed medical assistants can enter orders into the medical record for purposes of including the order in the numerator for the objective of CPOE…”
Q: How does CMS define “credentialed medical assistants”?
A: According to the 2012 CMS document cited immediately above, “Credentialing for a medical assistant must come from an organization other than the organization employing the medical assistant.”
Q: Does an associate degree, certificate, or diploma from an academic medical assisting program fall within the CMS definition of a credentialed medical assistant?
A: In my opinion, the context of the August 23, 2012 CMS final rule does not allow an associate degree, certificate, or diploma from a medical assisting program to be considered as a medical assisting credential. The medical assisting credential must be granted by a body that requires medical assistants to pass a standardized test.
Q: Would a “credential” based on experience and recommendations meet the CMS definition of a credentialed medical assistant?
A: No. The intent of CMS was that a medical assistant pass some sort of examination in order to fulfill the definition of a “credentialed medical assistant.”
Legal Eye 
So what is a credentialed medical assistant??? Can they be registered, and be considered credentialed??
According to CMS credentialed means that the medical assistant has passed a test given by an entity other than the medical assistant’s employer. Having the RMA of the AMT meets this definition.
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Do CCMA’s and NCMA’s also qualify as being “credentialed?” Since the CMA says that credentialed medical assistants can enter orders for CPOE purposes if they can originate order by state, local, and professional guidelines, does the requirements for credentialing differ by state, and if so, where could we find information about the necessary requirements by state?
Thank you for your question. I am happy to respond.
The CMS rule requires medical assistants to be “credentialed” in order to enter orders into the electronic health record for purposes of having such entry count toward meeting the meaningful use Core Objective under the Medicare and Medicaid Incentive Program. Any medical assisting credential awarded by an entity other than the medical assistant’s employer after passing an examination qualifies under the CMS rule.
To my knowledge, there are no state laws that impose limitations on which medical assistants providers are permitted to delegate the entering of medication, laboratory, and radiology orders into the EHR as specifically directed by the provider. Therefore, in all states, the CMS requirement pertaining to medical assistants being “credentialed” in order to enter orders into the EHR for meaningful use purposes is applicable.
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
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what test must be taken and where can it be found?
Thank you for your question. If you have graduated from a postsecondary medical assisting program accredited by either CAAHEP or ABHES, I would suggest that you take the CMA (AAMA) Certification Examination. Registration information is found on the AAMA website–www.aama-ntl.org
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
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I am a certified Medical assistant. I work directly under a physician, who delegates a lot of responsibility to me. I perform a lot of ancillaries in our office and I am wondering if I’m covered under his medical malpractice? Thank you
Thank you for your question. I am happy to respond.
Whether you are covered by the office’s or the physician’s malpractice policy depends on the wording of the policy. I would suggest that you ask your superiors whether you are covered by the policy, and to what extent you are covered. It may also be prudent to ask for a copy of the policy, or at least of the provisions that address coverage of allied health professionals working under physician supervision, to see the extent and the nature of the coverage.
I hope this is helpful. Please let me know how I 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
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I am a student and will graduate in July with my associates in medical assisting and will take my test in September. Right now I am doing my directed practice in a general surgeon office that is part of a large clinic. My question is, are the other ladies that are medical assistant but have no credentialing (they have been working for 18+ years) will be allowed to enter orders into the EHR to comply with meaningful use? Would the office actually have to have a CMA to comply with meaningful use, which I know the participate in.
Thank you
Leah Kohlhofer
Thank you for your question. In its final rule issued last year, CMS determined that only “credentialed medical assistants” are permitted to enter orders into the electronic health record for purposes of having such entry count toward meeting the meaningful use measures of the Medicare and Medicaid EHR Incentive Program. I will send you two of my articles that explain the CMS rule.
I hope you will find them 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
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Is SCMA http://www.specialtycma.com legit? Would this be a good choice for certification?
Thank you for your question. What we can say is that the Specialty Certified Medical Assistant-SCMA is not accredited by the National Commission for Certifying Agencies (NCCA), and is not affiliated in any way with the CMA (AAMA) credential granted by the Certifying Board of the American Association of Medical Assistants.
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
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My question i hope you can clarify is this i work for a large hospital im actually employed at a family practice through this hospital i went to a college accredited with the AAMA I have a 2 year associates degree and passed my test to be AAMA certified i was currently a CMA 3 With the new medicair laws the hospital gave all clinical assistants the choice to challenge the test and would be RMAs i was told today i could no longer put the C in front of the Ma and the years no longer mattered when i started i was told to be a CMA3 you had to have a two year degree and three years of experience i was told by higher management my education or credintials were no longer recgonized as being different,i have a hard time understanding how this can happen when i worked my ass off in a very demanding program and then took a 5 hour test the test they are taking now takes 30 mins to pass. I think the ones that went through the program and are AAMA certified should have the pay and respect and i feel like ive been cheated so a hospital could do a short cut to please Medicare laws. I would appreciate your feedback on this because i worked hard for my title and feel like im being cheated. Thanks.
I am very sorry to hear about this situation. Could you please tell me in what state you are located? Also, could you provide my within anything in writing about this from the employer? I would be better able to advise you after receiving any written material.
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
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Our CMO is wanting to train staff to become medical assistants, possibly getting them certified. We are in the state of Texas, and the laws are very vague. My question is, is it possible in the state of Texas, for the Chief Medical Director to train medical staff to become certified medical assistants? or qualify for them to be medical assistants?
Thank you for your question. I will have to attach several documents to explain the law in Texas, so I will send my response directly to your e-mail.
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
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If the employee is either a licensed healthcare professional or certified medical assistant, does it matter what their position title is called?
Thank you for your question.
To enter data into the HER under the Incentive Program, a health professional must be licensed or be a “credentialed medical assistant.” It does not matter what title is given to any professional.
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
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My understanding is that Florida statute states there are only two organizations that are acceptable for Medical Assistants to become certified. AMT and AAMA. Can you confirm? Thanks.
Thank you for your question. Here is the Florida medical assisting law:
The 2012 Florida Statutes
Title XXXII
REGULATION OF PROFESSIONS AND OCCUPATIONS Chapter 458
MEDICAL PRACTICE View Entire Chapter
458.3485 Medical assistant.—
(1) DEFINITION.—As used in this section, “medical assistant” means a professional multiskilled person dedicated to assisting in all aspects of medical practice under the direct supervision and responsibility of a physician. This practitioner assists with patient care management, executes administrative and clinical procedures, and often performs managerial and supervisory functions. Competence in the field also requires that a medical assistant adhere to ethical and legal standards of professional practice, recognize and respond to emergencies, and demonstrate professional characteristics.
(2) DUTIES.—Under the direct supervision and responsibility of a licensed physician, a medical assistant may undertake the following duties:
(a) Performing clinical procedures, to include:
1. Performing aseptic procedures.
2. Taking vital signs.
3. Preparing patients for the physician’s care.
4. Performing venipunctures and nonintravenous injections.
5. Observing and reporting patients’ signs or symptoms.
(b) Administering basic first aid.
(c) Assisting with patient examinations or treatments.
(d) Operating office medical equipment.
(e) Collecting routine laboratory specimens as directed by the physician.
(f) Administering medication as directed by the physician.
(g) Performing basic laboratory procedures.
(h) Performing office procedures including all general administrative duties required by the physician.
(i) Performing dialysis procedures, including home dialysis.
(3) CERTIFICATION.—Medical assistants may be certified by the American Association of Medical Assistants or as a Registered Medical Assistant by the American Medical Technologists.
History.—s. 7, ch. 84-543; s. 7, ch. 84-553; ss. 21, 26, ch. 86-245; s. 4, ch. 91-429; s. 28, ch. 97-264; s. 113, ch. 2007-5.
Note that the statute indicates that medical assistants “MAY,” not “MUST,” be certified by the AAMA or the AMT. So, this language does not REQUIRE medical assistants to have the CMA (AAMA) or the AMT(RMA). It just says they MAY have one of these two medical assisting credentials.
Because this Florida statutory language is recommendatory, and does not set up a requirement of certification for medical assistants, it is not correct to state that Florida law only recognizes the CMA (AAMA) and the RTA as requirements for medical assisting practice.
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
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There is a July 10th post on this thread from someone in Texas, to whom you replied that would send documents directly to her. I, too, am in Texas and would appreciate the information you shared.
I will send those to you immediately.
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
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The CMA (AAMA): Health Care’s Most Versatile Professional
I would appreciate the Texas information as well!
Thank you. I will send it to your e-mail address.
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
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The CMA (AAMA): Health Care’s Most Versatile Professional
Could you please send me the Texas information as well?
Donald, I would love to see those documents re: Texas as well. Thanks!
I will send them immediately.
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
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The CMA (AAMA): Health Care’s Most Versatile Professional
In our EHR, there is an option for MA’s to order labs/procedures/etc “on behalf of a provider”. Do they need to be certified to do this or is it okay since it is on behalf of a licensed physician or PA? Also, do CNA’s count as licensed professionals for the Meaningful Use CPOE criteria?
Thank you for your question. It raises some interesting issues which I am happy to address.
The fact that medical assistants are entering orders into the electronic health record (EHR) on behalf of a provider does not change the legal analysis. Indeed, all medical assistants, in every situation, may only enter orders at the specific direction of, and authorization by, a health care provider. Therefore, the following statements from my July-August 2013 Public Policy article in CMA Today are applicable:
Who can enter orders into the EHR for
meeting the Stage 1 and 2 measures?
Stage 1 of the Incentive Program specified
that only “licensed health care professionals”
could enter orders into the CPOE
system for meaningful use calculation
purposes. At the urging of the American
Association of Medical Assistants and
other parties, on August 23, 2012, CMS
issued a final rule allowing “credentialed
medical assistants” to enter orders into the
CPOE system for the purpose of calculating
compliance with this Core Objective.
The CMS Stage 2 Eligible Professional
Meaningful Use Core Measures document,
issued in October of 2012, includes the
following statement:
“Any licensed healthcare professionals
and credentialed medical assistants can
enter orders into the medical record for
purposes of including the order in the
numerator for the objective of CPOE…”
How does CMS define “credentialed
medical assistants”?
According to the 2012 CMS document
cited immediately above, “Credentialing
for a medical assistant must come from an
organization other than the organization
employing the medical assistant.” That
is, a clinic or health system cannot give a
“credential” to its medical assistants and
argue successfully that such a “credential”
meets the CMS requirements.
Therefore, in response to your question, all medical assistants entering orders into the EHR must do so on behalf of a provider. Secondly, in order for such entry to be counted toward meeting the meaningful use requirements under the Medicare and Medicaid EHR Incentive Program, such entry must be done by a “credentialed medical assistant.”
August 20 CMS posted the following Q & A on its website:
[EHR Incentive Programs] When meeting the meaningful use measure for computerized provider order entry (CPOE) in the Electronic Health Records (EHR) Incentive Programs, does an individual need to have the job title of medical assistant in order to use the CPOE function of Certified EHR Technology (CEHRT) for the entry to count toward the measure, or can they have other titles as long as their job functions are those of medical assistants?
If a staff member of the eligible provider is appropriately credentialed and performs similar assistive services as 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, he or she can use the CPOE function of CEHRT and have it count towards the measure. This determination must be made by the eligible provider based on individual workflow and the duties performed by the staff member in question. Whether a staff member carries the title of medical assistant or another job title, he or she must be credentialed to perform the medical assistant services by an organization other than the employing organization. Also, each provider must evaluate his or her own ordering workflow, including the use of CPOE, to ensure compliance with all applicable federal, state, and local law and professional guidelines.
Created: 08/20/2013
(FAQ9058)
I take this to mean that a certified ophthalmic assistant or a certified podiatric medical assistant would be considered a “credentialed medical assistant” under the CMS rule. However, I don’t think the above CMS Q & A would apply to a certified nursing assistant. I come to this conclusion because of the following sentence:
Whether a staff member carries the title of medical assistant or another job title, he or she must be credentialed to perform the medical assistant services by an organization other than the employing organization.
I would argue that a certified nursing assistant is NOT “credentialed to perform medical assistant services.”
This is my best legal interpretation. 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
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Will you e-mail me the Texas information as well? Thank you!
Lovely material. Thanks!
Does the state of Florida recognize the credentialing of Medical Assistances for CPOE use?
Thank you for your question. Florida law does permit physicians to delegate to competent and knowledgeable medical assistants the entry of orders into the electronic health record. Florida does not require medical assistants to be credentialed in order to work. However, increasing numbers of employer are insisting on hiring CMAs (AAMA). There are good legal reasons for doing so, and I will send you one of my articles that elaborates on this point.
The CMS requirement that only “credentialed medical assistants” (in addition to licensed health care professionals) are permitted to enter medication, laboratory, and radiology orders into the CPOE system and have such entry count toward meeting the meaningful use requirements under the Medicare and Medicaid Incentive Programs is federal law.
I hope this is helpful. I will send my article to your e-mail address.
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
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The CMA (AAMA): Health Care’s Most Versatile Professional
I believe that after reading above I’ve answered my own question; that being said, a new questions arises. Since it is NOT MANDATORY for Florida CMA’s to be credentialed (state, local laws) then they do not count as “credentialed” staff for entering CPOE. Correct? And by “credentialed” in Florida, who is included in that? RN’s???
Thank you for your follow-up question. I just answered your previous question.
CMS rule requires medical assistants to be “credentialed” in order to enter orders into the CPOE system and have such entry count toward meaningful use. Having a current CMA (AAMA) credential meets the CMS definition of “credentialed medical assistant.”
Licensed health care professionals such as RNs and LPNs are also permitted to enter orders into the CPOE system and have such entry count toward meaningful use.
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
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The CMA (AAMA): Health Care’s Most Versatile Professional
Excellent!! Thank you for both reply’s as well as the email! I appreciate your prompt response!
You are very welcome!
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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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
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The CMA (AAMA): Health Care’s Most Versatile Professional
We are trying to understand the guidelines in Texas on CPOE as it relates to “credentialed medical assistants”. Can you forward your information on Texas?
Thank you for your question. It is my legal opinion that Texas law permits physicians to delegate to competent and knowledgeable medical assistants working under their direct supervision in outpatient settings the entering of medication, laboratory, and radiology orders into the CPOE system. However, for this entry to count toward the meaningful use thresholds under the Medicare and Medicaid Incentive Programs, the medical assistants must be credentialed.
I will forward the documentation to your e-mail address.
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
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Could you address your thoughts in regards to EMT’s that work in medical offices and CPOE. I understand that they pass a CAHEP approved certification exam and then have to be licensed to practice in their state. So would their work count towards CPOE. Thank you!
I’d like to know this as well.
When entering orders into the Electronic Medical Record, does the Medical Assistant that is entering the order have to be credentialed if the Provider is signing off on the order after it us entered by the Medical Assistant.
Great posts- The term credential meaning? Current or attended a accredited school and past the test. What if it was 2, 4, 5 year prior. Would that excluded them from the title of “credential”
Thank you for your question. According to CMS, an individual must have a third-party credential demonstrating the knowledge required to enter orders into the CPOE system. A third-party credential is one that is issued by an entity other than the employer of the individual.
CMS does not put a recency requirement on when the credential was acquired. However, only current CMAs (AAMA) are permitted to use the CMA (AAMA). Therefore, a CMA (AAMA) who is not current does not meet the CMS requirement.
I hope this is helpful.
Donald A. Balasa, JD, MBA
Chief Executive Officer, Legal Counsel
American Association of Medical Assistants
Ph: 800/228-2262 | Fax: 312/899-1259 | http://www.aama-ntl.org
The CMA (AAMA): Health Care’s Most Versatile Professional®
In the state of Iowa, can a CNA room patients, enter vitals into the EHR, give injections (vaccines) and administer meds in the clinical setting?
Thank you for your question. Are you asking whether Iowa law permits physicians to delegate to certified nursing assistants (CNAs) working under their direct supervision in outpatient settings the tasks you list below?
Donald A. Balasa, JD, MBA
Chief Executive Officer, Legal Counsel
American Association of Medical Assistants
Ph: 800/228-2262 | Fax: 312/899-1259 | http://www.aama-ntl.org
The CMA (AAMA): Health Care’s Most Versatile Professional®
Correct. She directly works under myself (a nurse practitioner) but there are physicians in house.
Thanks
Thank you. This is a bit of a tricky legal question, so I will send my response and several attached documents and articles to your e-mail address.
Donald A. Balasa, JD, MBA
Chief Executive Officer, Legal Counsel
American Association of Medical Assistants
Ph: 800/228-2262 | Fax: 312/899-1259 | http://www.aama-ntl.org
The CMA (AAMA): Health Care’s Most Versatile Professional®
Thank you
Welcome!
Donald A. Balasa, JD, MBA
Chief Executive Officer, Legal Counsel
American Association of Medical Assistants
Ph: 800/228-2262 | Fax: 312/899-1259 | http://www.aama-ntl.org
The CMA (AAMA): Health Care’s Most Versatile Professional®
Never got your attachments…
I am sorry. I will send again.
Donald A. Balasa, JD, MBA
Chief Executive Officer, Legal Counsel
American Association of Medical Assistants
Ph: 800/228-2262 | Fax: 312/899-1259 | http://www.aama-ntl.org
The CMA (AAMA): Health Care’s Most Versatile Professional®
I graduated from Everest College Phoenix. I completed the medical assisting program but they are NOT accredited by either CAAHEP or ABHES. Because of this, I am not able to become a CMA through the AAMA. What are my options?