Who can Enter Orders Into the CPOE System?

I have been receiving questions about which licensed health professionals are permitted by CMS rule to enter medication, laboratory, and radiology orders into the CPOE system. What follows is an excerpt from CMS FAQ 9058, which addresses the matter:

“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 certified EHR technology (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.”

Many of the individuals about whom I have received questions (e.g., radiologic technologists or athletic trainers) possess state licenses, making them “appropriately credentialed.” However, the central question is whether the individual possesses sufficient knowledge to handle any alerts that may appear when entering orders into the CPOE system. The eligible provider (EP) must make that decision, and that EP will be held accountable for that decision.

Please feel free to contact me with your continued questions on this matter.

About Donald A. Balasa

Donald A. Balasa, JD, MBA, chief executive officer and legal counsel for the American Association of Medical Assistants, keeps his eye on what is happening in the profession.
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56 Responses to Who can Enter Orders Into the CPOE System?

  1. Patsy Johnson, MA. says:

    I do not have a current certification for my medical assistant degree. I let my certification expired. According to this article, will I need to be recertified? Georgia regulations does not restrict medical assistants from performing any specific medical assisting tasks. Medical assistants work under the direct supervision of physicians and are allowed to perform those tasks which are directed and supervised by the physician.
    What will this have to do with me being a MA, I put vaccines into the system, but I do not give the vaccines, but I do put all the vaccines information into the computer. Will I have to be recertified? Also, we have other medical asssistants and phlebotomists working in the office. Are they allowed to put information in the computer under the physicians? Will phelobotomist have to be certified? What is the rule on this?
    I have been searching for information, but I’m having a hard time finding the correct information. Please answer ASAP through email.

    Thanks,

    patsy.srhc@gmail.com

    • Thank you for your question. I am happy to answer your questions.

      The CMS rule is federal law. Regardless of Georgia law, in order to enter medication, laboratory, or radiology orders into the Computerized Provider Order Entry (CPOE) system and have such entry count toward meeting the meaningful use requirements under the Medicare and Medicaid EHR Incentive Programs, the individual must be a “credentialed medical assistant” (or a licensed health professional). If the credential you held was the CMA (AAMA), you must recertify and maintain the currency of your CMA (AAMA) in order to qualify as a “credentialed medical assistant” under the CMS rule.

      The CMS rule applies to all individuals who enter these three types of orders into the CPOE system for meaningful use purposes. They must be either “credentialed medical assistants” or licensed health professionals.

      This requirement is not in place for individuals who enter demographic, financial, or “non-order” information into the CPOE system.

      I hope this is helpful. I will forward to your e-mail address some of the articles I have written on this subject. I will also forward you the link to the three videos of the joint presentation that Mr. Anthony of CMS and I gave at the 2013 AAMA Annual Conference.

      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

  2. Mary Fox says:

    Dear Mr. Balasa,

    I am a Registered Nurse in a specialty outpatient clinic. We deal with patients who tend to have numberous comorbid conditions, which require regular management by our physician. I was just advised by my manager that Certified Medical Assistants may take verbal medication and other orders from a physician, and carry them out. (ie. Write the verbal order in the Electronic Medical Record, without a physican signature, and set them up to be filled, etc.)
    I have some concerns with this, as a medical assistant does not have the training to determine a potential issue with dosage, nor have the critical thinking skills that go along with that. We have wonderful medical assistants in our department, and they are very valuable to our process. However, more and more, I see hospitals and facilitites replacing seasoned, well trained Registered Nurses, with Medical Assistants, and having those Medical Assistants do things that are RN tasks and require more education than what a Medical Assistant has.
    Please help me understand here. Are these CMA’s going to be actually taking verbal orders and processing them, as an RN would do? Or, are they taking an order that is written by the physician, and acting as a scribe to simply transfer it into the EMR?
    What about narcotics and other medications that fall under the scheduled drugs guidelines?
    What about IV orders, or feeding tude orders?
    Help me understand the logice behind this move, aside from it being less expensive for an organization to use a CMA, instead of an RN. For instance, as an RN in our clinic, I have done patient RN visits for 12 years. The have now shifted that, and are having the Medical Assistants do weekly clinical visits, which actually require clinical judgement that they do not receive in their training. I am really trying to get my arms around this thing, especially when I am told that those MA’s are working under my license. I don’t believe that this is appropriate, since I am not the one making a decision as to which items are being delegated.

    Thank you for your help with clarifying this subject for me.

    Sincerely,

    Mary Fox, RN

    • Thank you for your questions and comments. I will answer some of your questions here. Some of your questions require a lengthier explanation and references to documents. I will answer these questions by sending you an e-mail.

      First of all, under the laws of all states, medical assistants—even CMAs (AAMA)—are not permitted to issue any orders at their own initiative and based on their own judgment. Medical assistants are permitted to enter orders as specifically directed to do so by the overseeing/delegating/supervising provider (usually, a physician, nurse practitioner, or physician assistant). The delegating provider must review, approve, and sign/attest the orders before they are transmitted.

      Secondly, medical assistants are not permitted to do anything that constitutes the practice of medicine. Also, they are not permitted to do anything that requires them to exercise independent professional judgment, or to make clinical assessments, evaluation, or interpretations.

      Medical assistants who have graduated from a CAAHEP or ABHES accredited medical assisting program, and who have passed the CMA (AAMA) Certification Examination, have been awarded the CMA (AAMA) credential, and have kept the credential current by meeting the continuing education or retesting recertification requirements of the Certifying Board of the AAMA, have demonstrated competence and knowledge in the areas taught in their academic program and tested on the CMA (AAMA) Certification Examination.

      I hope this is a helpful first step in answering your questions. As promised above, I will e-mail you now.

      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

      • Greg Bodager says:

        Mr. Balasa,

        Would you please email me the legal opinion letter for Kentucky and some other pertinent documents and articles as well? I’m an RN and Director of our Cancer Center, and I want to make sure I’m supporting our CMA’s appropriately.

        Thanks so much,
        greg

      • Thank you for your question. I will send the Kentucky information 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®

      • Libby Mauzy says:

        Mr. Balasa,
        I am a new clinic manager in KY, though I have been a Nursing Supervisor for inpatient for many years. With the clinics current EHR, nurses and CMA are able to place orders under direction of a physician. The order does not have to be “reviewed” by the physician before it is put into action. This includes medications! The order is sent to an “Inbox message” of the provider to eventually sign. I have serious concerns with this process. It has taken some adjustment on my part understanding that CMAs are able to take/place orders, when in the hospital setting CNAs are not allowed to. I have witness medication errors from skilled nurses. My worry is intensified at the thought of CMAs errors related to orders/medications. I have pushed for the orders to be “pended” prior to even being put into action. I am receiving push back from physicians because #1 delay in patients receiving medications until provider has “signed” the order and #2 possibility of disrupting standing orders/protocols.

        In my opinion safe quality care comes first! I was attempting to find studies or documentation to support my suggestion to the Administration and ordering committee. That’s when I came across your article. Your statement to Ms. Fox, “The delegating provider must review, approve, and sign/attest the orders before they are transmitted” is exactly the kind of information I am looking for.

        I would GREATLY appreciate any guidance or documentation you have.

        Thanks in advance!

    • Mike Williams says:

      Mr. Balasa,

      Would you please send me any information you could involving this topic for Tennessee? We have quite a few Medical Assistants and I would appreciate your perspective as we continue to develop our program.

      • Thank you for your question. It is my legal opinion that Tennessee law permits physicians to assign to knowledgeable and competent medical assistants working under their direct supervision in outpatient settings the entering of medication, diagnostic imaging, and laboratory orders into the CPOE system. I will send my legal opinion letter for TN 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®

  3. Mary Fox says:

    Thank you very much, Mr. Balasa. I look forward to your email.
    Mary Fox, RN

    • Heidi Chamberlain, RN says:

      I would love to know what info was in that email. I am an RN trying to understand how MAs can take verbal orders….

      • Thank you for your comment. I would be happy to send you my scope of practice legal opinion letter if you would provide me the state in which you are located.

        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®

      • Heidi Chamberlain, BSN, RN says:

        Good morning,
        I am in California. Myself and our RN staff of 28 are struggling with the idea that our 14 MAs can place orders into EHR based on verbal orders from the clinician or based on written protocol that our clinic has developed. One of my concerns is – just because someone makes a policy doesn’t make it legal. The MA scope is so ambiguous….
        Any insight would certainly help me sleep better at night, thank you.
        Heidi Chamberlain, BSN, RN
        Clinical Nurse Education Manager

      • Thank you for your question. I have a letter, some documents, and some articles that I will forward to your e-mail address. These should answer most of your questions.

        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®

      • Amy Scales, Clinical Manager says:

        Mr Balasa, Could you also provide me the information and your scope of practice legal opinion letter. I am located in Kentucky. My email is ascales@methodisthospital.net

      • Yes. I will e-mail you my legal opinion letter for Kentucky and some other pertinent documents and articles.

        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®

      • Amy, I just sent the information but I received an error message.

        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®

      • Cortney Chowning, RN Quality Risk Manager says:

        Mr. Balasa, I am also very interested in your legal opinion letter for Kentucky and other pertinent documents and articles. Thank you ! cchowning@ccmhosp.com

      • Thank you! I will send you my legal opinion letter for Kentucky and other pertinent documents and articles.

        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®

  4. Carol Rendon says:

    I hace medical assistant’s that have diploma from their college stating they completed studies in medical assistant. Does tht make us compliant?

    • Thank you for your question. The answer is a bit complicated and lengthy, so I will respond 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

      Visit us on Facebook! http://www.aama-ntl.org/facebook

      The CMA (AAMA): Health Care’s Most Versatile Professional

      • Cheryl Smith says:

        The question from Carol Rendon :I have medical assistant’s that have diploma from their college stating they completed studies in medical assistant. Does this make us compliant? This is a question I would also like answered. We required all MAs to have a certificate from a credential CA school, but not the State Certificiation as a CMA. Do our MA staff quailify for CPOE. Thank you

      • Thank you for your question. The answer is a bit complicated, so I will respond directly to you via 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

        Visit us on Facebook! http://www.aama-ntl.org/facebook

        The CMA (AAMA): Health Care’s Most Versatile Professional

  5. Dee Jenkins says:

    I have medical assistants in my practice who are older and were trained by physicians as a MA.(probably before the days of MA schools)
    She has worked as a dermatology MA for 30 years but does not have any “official” training. Will she be unable to continue to work under this new system? What can she do to become certified? I have other MAs who have been to school but have not kept up their certification because it was not previously required. Is that going to be a requirement under the new guidelines? If a MA is not certified what are they allowed to do and not do under the new guidelines to be compliant. Please be as specific as possible. Thank you

  6. Christy Reuber RN says:

    Our organization borders Wisconsin and Illinois where we have CMA’s working in both states. If we have protocols that are signed by our providers can our CMA’s put in orders into the CPOE without pending the order for the provider to sign? We have Epic as our EHR and our MA’s can either pend or sign orders and get a co-signature after the order has been released. Any information that you can provide would be helpful.

    • Thank you for your question. My position is that medical assistants, under the laws of all states, must pend orders until the overseeing/delegating/supervising provider reviews, approves, and signs/attests to the order.

      Note the following excerpt from my May-June 2013 article in CMA Today:
      Does this mean that physicians are
      permitted to delegate any duties to a
      medical assistant as long as they are
      done under direct physician supervision?
      No. Medical assistants cannot be delegated
      any duties that: (1) constitute the practice
      of medicine or require the skill and
      knowledge of a licensed physician; (2) are
      restricted in state law to other health professionals;
      (3) require the medical assistant
      to exercise independent professional
      judgment or to make clinical assessments,
      evaluations, or interpretations.

      It is position that a medical assistant transmitting a final, actionable order prior to review and approval by a health care provider would be the exercise of independent professional judgment and the making of clinical assessments, evaluations, or interpretations.

      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

  7. Nancy says:

    My question is simple, may a RN in Alabama enter CPOE orders under the direction of a physician (his scribe) and it count toward Meaningful Use Stage 2? Our setup has a RN rounding with our hospitalists and taking down his orders. In turn, he reviews and signs them. I was just told this is not allowed. I would appreciate your comments.

    • Thank you for your question. I am happy to help. I am able to speak to what CMS allows for meaningful use calculation purposes. I cannot speak to what the policy of the particular hospital permits.

      CMS issued a rule stating that only licensed health care professionals and “credentialed medical assistants” are permitted to enter medication, laboratory, and radiology orders into the CPOE system and have such entry count toward meeting the meaningful use thresholds under Stages 1 and 2 of the Medicare and Medicaid Incentive Programs. Because a registered nurse is a licensed health care professional in all states, RNs are permitted to enter orders into the CPOE system (as directed by the overseeing provider) and have such entry count toward meaningful use.

      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

  8. Nancy says:

    Thank you for your speedy reply. If I may have follow-up questions. 1) Are PharmD’s allowed to enter CPOE orders? We currently scan our medication orders to the pharmacy via Pyxis Connect (like a smart fax machine) then the PharmD’s enter these orders via their physician pathway. This is the first actionable order because by hospital policy the pharmacists review and reconcile all medication orders for accuracy, allergies, interactions, etc. They can make simple substitutions or contact the prescribing physician if there are contraindications. In short, the prescribing physician writes the order but the pharmD places the order into the system to actually administer the dose.

    2) On the topic of nursing entering physician orders – the question is now whether the nurse should use her own log in and direct the order to the physician’s queue to sign OR does she log in as the physician and enter those orders? I sincerely appreciate you for taking time to answer these!

    • You are welcome. I am happy to answer these additional questions.

      A licensed pharmacist is permitted to enter orders into the CPOE system.

      A nurse should use her/his own log in and direct the order to the physician’s queue for the physician’s review, approval, and attestation/signature.

      Once again, 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

  9. Paul says:

    Mr. Balasa,

    Hi. I am a specialist MD in the state of Alabama. Our office is currently using a EHR. I have a somewhat time consuming and daunting process with all of the computerized order entry in addition to my other documentation responsibilites. I have delegated this to my Certified Medical Assistant at this time by producing a paper sheet that I carry into the room with me and check off any orders for labs, radiology, nerve studies/EMGS, EEGs therapy/occupational/speech referrals, neuro subspecialty or other specialty consult referrals as needed (with reasons) as well as an ICD 9 code (aware that will change to ICD 10 in the future) and a billing code (i.e. 99213, 99214, etc.) as well as follow up time period i.e F/U 1month. I then pass this form on to my certified MA upon exiting the room so that she may enter these orders, codes and followups in herself while I go to my station and dictate their HPI, PE, ROS, and I enter the med orders myself just as a personal preference) and then move on to the next room to facilitate a speedier discharge of the patient. It has drastically improved our office workflow and cut wait times by nearly 45 minutes. Is there anything I am doing incorrectly that you can identify that I might improve– for example is there anything I am currently having the certified MA doing that will not meet meaningful use. I want to make sure that I am within the rules and regulations in these most confusing times.

    Thank you again.

    • I sympathize with your situation, Doctor and thank you for the care you provide during these complicated and changing times!

      I find nothing in what you have recounted below that violates any of the CMS rules about order entry into the CPOE system for meaningful use. I will send to your e-mail a recent post that addresses these issues in greater detail.

      I hope this is helpful, Doctor. Once again, we appreciate your service to the American public!

      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

  10. Mary Marks says:

    Mr. Balasa,
    How does the CMS rules about order entry into the CPOE system for meaningful use affect medical assisting students on externship?

    • Thank you for your question. A medical assisting student has not yet obtained a medical assisting credential, and therefore is not permitted to enter orders on the practicum and have such entry count toward meeting this meaningful use threshold under the Medicare and Medicaid Incentive Programs.

      However, if delegated by the provider at the practicum site, the student is permitted to enter orders into the CPOE system and not have such entry count toward meaningful use. Note the following excerpt from my Public Affairs article in the July-August 2013 CMA Today:
      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”?
      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.
      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.

      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

  11. Linda Lee Headrick says:

    I have a certified nurse assistant that has worked in Wyo as an MA- can she enter vitals, injections, medication lists, refills, allergies into EMR as a CNA?

    • Thank you for your question. As stated by Robert Anthony of CMS during our joint presentation last September before the House of Delegates, the CMS rule permits “anyone” to enter factual data (such as medication lists, vital signs, demographic information, list of allergies) into the electronic health record. However, only “credentialed medical assistants” and licensed health care professionals are permitted to enter medication, laboratory, and radiology orders into the CPOE system.

      I would suggest that you contact the Wyoming agency that regulates nursing assistants and ask whether CNAs are considered to be licensed under WY law. If they are not considered licensed, then they cannot enter the three types of orders into the CPOE system and have such entry count toward meeting the meaningful use requirements under the Medicare and Medicaid Incentive Programs.

      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

      • MistyArnett says:

        Mr Balasa

        I also have an question regarding CNA placing orders in EHR. I work in an physicians office that only enters orders into EHR under physician instruction. I have contacted the Indiana agency that regulates CNA’s. They state that CNA’s should not be working in doctors offices, if they are then they can not renew their can license. I know of several cna’s working in doctors offices. Can you tell me what guidelines you have on cna’s entering orders into EHR under physician direction? Thanks

      • Thank you for your question. I have a specific opinion with documentation about whether certified nursing assistants are permitted to enter orders into the CPOE system for meaningful use calculation purposes. I will send it to your e-mail.

        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®

  12. Jan says:

    I have been working as a Medical Assistant for 33 years as a graduate of Bryan Institute for Medical Assisting. I have misplaced by diploma and the school has closed. I had not taken the certification test . I have tried to get a copy of my diploma with no luck. I now need to get certified/ registered as a Medical Assistant for my current employer and need to know what I need to do this. I appreciate any help you can offer.
    Thank You

  13. Jessica says:

    Can a nationally certified and state(Texas) registered Pharmacy Technician enter medications refill and new medication orders based on verbal or written order by physician. I have worked as tech for 12 years and in a Dr Office for 4 years as the prescription coordinator

    • Jessica says:

      In regards to the meaningful use CPOE objective

    • Thank you for your question. Note the following FAQ on the CMS 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)
      It is my legal opinion that your state and national pharmacy technician certifications would most likely meet the CMS requirement of a “credentialed medical assistant.” As stated by CMS above, your overseeing/delegating/supervising physician would have to make the final determination.

      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

  14. Kim says:

    This question goes back to certified nursing assistants. In your previous reply you suggested that we check with state regulations to see if they consider this group to be a licensed professional. The state of WI is not very clear on many of the roles, and they appear to be “silent” on the ruling. If education, training and credentialing is similar to CMA’s, why wouldn’t these roles be acceptable for entering orders?

    • Thank you for your question. Note the following CMS FAQ:
      [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)

      Certified Nursing Assistants are indeed credentialed. However, the question is whether they are “appropriately credentialed to perform medical assistant services.” In my opinion, the language of the CMS rule and of the above FAQ does not resolve this question. It is up to each employer to determine whether the CNA is indeed competent and knowledgeable in electronic order entry.

      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

  15. E.Williams says:

    Hello,
    I work in an outpatient practice as an Executive Assistant however in addition to my admin duties, I handle small clinical tasks in the ERM such as routing rx refill requests, or entering rx refills requests that i receive by phone. Outside of my day job I’m in the process of becoming a certified pharmacy tech, as such would I be allowed to continue to enter in refill requests in EMR and would that meet the MU benchmark?

    • It is my legal opinion that, once you become a certified pharmacy technician, eligible professionals are permitted to delegate to you the entry of medication orders into the CPOE system as specifically authorized by the EP. Such entry can then count toward MU. Don

      Sent from my iPhone

    • It is my legal opinion that a certified pharmacy technician is permitted to enter orders into the CPOE system at the direction of a licensed provider and have such entry count toward meeting the meaningful use thresholds under the Incentive Programs.

      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

  16. Josh Kimball says:

    We use scribes in our clinics. These scribes have been certified and do not enter orders without the physician in the room. At the end of the visit, the physician varifies all entries in the EMR by the scribe and signs off on the note. Can the scribes enter orders, but not commit the orders and leave it for the physician to do, and will this comply with meaningful use?

    • Thank you for your question. It is my understanding that CMS will be issuing some clarification within the next week about scribes entering orders for meaningful use purposes. As soon as the CMS statement is released, I will answer your question and forward the CMS opinion.

      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

  17. Robin Klotz says:

    Hi, I’m just finding out about this! I am a CPT through the National Phlebotomist Association. I also have a MA certificate but not credentialed through the AAMA. Can I enter orders into the CPOE, if so am I limited to only certain orders? Does it count as MU’s? Thank you in advance
    -Robin

    • Thank you for your question. The following FAQ from the CMS website provides the most authoritative answer to your question:
      [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 [i.e., meaningful use], 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 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®

      [cid:image003.jpg@01CFF8F0.5DE79010] [cid:image007.jpg@01CFF8F0.5DE79010] [wordpress] [mail]

  18. Rupali Drewek says:

    Are nurses allowed to act as a scribe? Can they translate written orders from a secure health message or progress note into orders on behalf of the physician during clinic visits? With our EHR, the physician would then import that order into his/her note verifying agreeing that this was entered correctly. Thanks in advance for your help.

  19. Libby Mauzy says:

    Mr. Balasa,
    I am a new clinic manager in KY, though I have been a Nursing Supervisor for inpatient for many years. With the clinics current EHR, nurses and CMA are able to place orders under direction of a physician. The order does not have to be “reviewed” by the physician before it is put into action. This includes medications! The order is sent to an “Inbox message” of the provider to eventually sign. I have serious concerns with this process. It has taken some adjustment on my part understanding that CMAs are able to take/place orders, when in the hospital setting CNAs are not allowed to. I have witness medication errors from skilled nurses. My worry is intensified at the thought of CMAs errors related to orders/medications. I have pushed for the orders to be “pended” prior to even being put into action. I am receiving push back from physicians because #1 delay in patients receiving medications until provider has “signed” the order and #2 possibility of disrupting standing orders/protocols.

    In my opinion safe quality care comes first! I was attempting to find studies or documentation to support my suggestion to the Administration and ordering committee. That’s when I came across your article. Your statement to Ms. Fox, “The delegating provider must review, approve, and sign/attest the orders before they are transmitted” is exactly the kind of information I am looking for.

    I would GREATLY appreciate any guidance or documentation you have.

    Thanks in advance!
    ..sorry for the second post, covering my bases incase I did it incorrectly:)

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