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.