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: Do medical assistants have to be credentialed to enter medication, laboratory, and radiology orders into the EHR if such entry is not being counted toward meeting the measure for the Core Objective “CPOE for Medication, Laboratory, and Radiology Orders”?
A: No. There is no other CMS regulation, federal law, or state law that requires medical assistants to be credentialed as a prerequisite for entering orders into the Electronic Health Record if such entry is not being counted toward meeting the Stage 1 and Stage 2 percentage requirements for entering orders into the CPOE. In other words, the absolute legal requirement is that medical assistants be credentialed (as defined in the CMS final rule) when entering orders for calculating compliance with the “CPOE for Medication, Laboratory, and Radiology Orders” Core Objective.
Q (part 1 of 2): When does the CMS final rule allowing credentialed medical assistants to enter orders into the CPOE go into effect?
Q (part 2 of 2): Does the CMS final rule only apply to entry of orders under Stage 2 of the Incentive Program?
Note the following answer to CMS FAQ 7693:
We [CMS] have revised the description of who can enter orders into the EHR and have it count as CPOE and have it count for purposes of the CPOE measure. This revision is available for EHR reporting periods in 2013 and beyond regardless of what stage of meaningful use the provider is attesting to. [Emphasis added.]
A (part 1 of 2): The CMS rule allowing credentialed medical assistants to enter medication, laboratory, and radiology orders into the computerized provider order entry (CPOE) system is in effect for reporting periods in 2013. It is not correct to assert that the CMS rule does not go into effect until 2014.
A (part 2 of 2): The above CMS FAQ clearly states that the rule allowing credentialed medical assistants to enter orders into the CPOE applies to all stages of the Medicare and Medicaid Incentive Program. Thus, it applies to Stage 1 as well as Stage 2, and will apply to Stage 3 when it goes into effect.