Certification and the CMA (AAMA) Credential, On the Job, Scope of Practice

General Entry vs. CPOE in the Electronic Health Record

Donald A. Balasa

As discussions about the CMS Stage 2 rule continue, one question that persists is whether non-credentialed medical assistants–and by extension, lay people–can enter orders into the electronic health record (EHR). What entries can such workers make, if any?

Robert Anthony of the CMS Health IT Initiatives Group touched on this topic during our joint presentation at last year’s AAMA Annual Conference. In short, the only meaningful use objective that carries a requirement as to who physically enters orders is computerized provider order entry (CPOE). The full text of Mr. Anthony’s response follows, with video:

For all of these objectives except computerized provider order entry, there really isn’t a requirement about who enters that information into an EHR, or who takes a particular action at all. Anybody can really do that. The only objective that there are any requirements around who does the actual entering for the EHR is that CPOE.

* * *

There are two different processes here. One is for entering something like blood pressure, or height/weight. Anybody can do that. Absolutely anybody can do that. In fact, there are many systems that are part of larger organizations where they’re not entering that information at all;they’re actually  getting that information from another system, especially demographic information that’s being loaded from a practice management system automatically. But when it comes to CPOE, we are very specific about who enters that information. The information either has to be entered by a licensed health care professional–and has to be done prior to any action being taken on the order–or it has to be entered by a [credentialed] medical assistant. You can’t have a lay person who enters that, somebody who goes through and just clicks a button. You have to have the actual licensed health care professional or [credentialed medical assistant].

Published by Donald A. Balasa

Donald A. Balasa, JD, MBA, CEO and legal counsel for the American Association of Medical Assistants, keeps his eye on what is happening in the profession.

33 thoughts on “General Entry vs. CPOE in the Electronic Health Record”

  1. Hi Don:
    An RMA(AMT) is an acceptable credential for entering CPOE, right?

    (I probably should know this, but just double checking).

    Kathy Zabel
    Medical Assisting Program Chair
    402-437-2756

    Reply

  2. LICENSED REGISTERED RADIOLOGIC TECHNICIAN… AM I CONSIDERED A “QUALIFIED MEDICAL ASSISTANT/HEALTHCARE PROFESSIONAL?”

    Reply

    1. The CMS rule states that only “credentialed medical assistants” or “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 thresholds under the Medicare and Medicaid EHR Incentive Programs.

      As a licensed registered radiologic technician, you fall within the category of licensed health care professionals. Therefore, you are able to enter orders as directed by your 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

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  3. Pingback: The Cost of Improper CPOE | Legal Eye

  5. Donald, we are having an internal debate in our office where our Internal Medicine department, for the most part, employs certified MAs. Washington state specifies in the MA scope of practice that “a medical assistant-certified may only administer medications if the drugs are:

    (A) Administered only by unit or single dosage, or by a dosage calculated and verified by a health care practitioner. For purposes of this section, a combination or multidose vaccine shall be considered a unit dose;

    (B) Limited to legend drugs, vaccines, and Schedule III-V controlled substances as authorized by a health care practitioner under the scope of his or her license and consistent with rules adopted by the secretary under (f)(ii) of this subsection; and

    (C) Administered pursuant to a written order from a health care practitioner.”

    This sets up the argument from some in the office who say that our MAs cannot queue up the orders for the docs in the EHR, whereas the docs believe they can give MAs verbal orders coming out of an exam room to give vaccines or injections and then the MA can queue up the order for them in the EHR and then route the order to them to review and sign off. The docs believe that reviewing and signing off on the order in the EHR constitutes a “written order,” whereas the managers take the statute at face value and interpret it to mean the docs must go through all parts of the order themselves.

    On the surface, this may not seem like a huge deal, but it is a tremendous workflow concern for the docs if they have to queue up all orders themselves in the EHR (many clicks), which would delay them being able to get to the next patient waiting. At 20 minutes per patient, including taking and recording vitals, history, doctor face time with the patients, clicking on orders and documenting the record–you can see where I’m going with this….

    Please provide some concrete guidance here for us. Thanks.

    Reply

    1. Thank you for your question. I can see why there would be uncertainty.

      I will send you the e-mail address of Brett Cain of the WA Department of Health. It is best for you to receive an authoritative and definitive interpretation of the Washington regulation from the WA DOH.

      I will e-mail you right 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

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  6. Pingback: Clinical Decision Support Alerts and Credentialed Medical Assistants | Legal Eye

  7. The healthcare system I am employeed by in NC states that as long as you are a CNA (certified nursing assistant) that you can enter into CPOE. Is this true? I have proudly been a CMA since 2009?

    Reply

    1. 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. If the nursing assistant is, then it appears that the CNA is permitted to enter orders 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

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  8. So one would qualify as long as they are credentialed by a third party and perform clinical duties?
    What about a certified electronic health record specialist (CEHRS) who works strictly in a clinical aspect assisting the physician?

    Reply

    2. Thank you again for your question. The following is an FAQ from 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)
      Based on the above FAQ language, it is my opinion that the issue is whether someone holding the CEHRS credential is “appropriately credentialed.” I have reviewed the NHA CEHRS 2011 Detailed Test Plan. Because the CEHRS examination does not test medical terminology and basic anatomy and physiology, it is my opinion that the CEHRS credential would not constitute an “appropriate credential.” Therefore, I do not believe that someone holding the CEHRS credential would fall within the definition of “credentialed medical assistant” as delineated in the CMS rule, and as clarified in the above FAQ.
      I hope this is helpful. I do not have the authority to make definitive judgments on what credentials CMS would and would not accept. Also, note the last sentence of the above FAQ:
      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.

      Nevertheless, this is my 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

      Reply

        1. Thank you for your question. My best opinion is that individuals having the CMAA of NHA would be considered “credentialed medical assistants” under the CMS rule.

          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

          Reply

  9. In the State of New Jersey, it appears that a certified Medical Assistant can enter into CPOE in the EHR, correct? When it comes to e-prescribing, who can generate the prescription and who can send the prescription to a participating pharmacy in the EHR?

    Reply

    1. Thank you for your question. According to New Jersey law and the CMS rule, “credentialed medical assistants” (as well as 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 thresholds under the Medicare and Medicaid Incentive Programs.

      Similarly, for meaningful use purposes, only a credentialed medical assistants (or licensed health care professional) is permitted to enter electronic prescriptions. These orders must be pended and cannot be actionable and transmitted until reviewed, approved, and attested to/electronically signed by the eligible provider.

      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

      Reply

  11. Hello I am a medical assistant in Arizona, now i have a question by the term “Certified Medical Assitant” you are referring to someone certified by AAMA or AMT right? And if they are not, does the entering in COPE, refer only to the meaningful use or the whole COPE in general?

    Reply

    1. Thank you for your question. The CMS definition of credentialed medical assistant includes medical assistants who hold the CMA (AAMA) or RMA(AMT) certifications. According to CMS, only “credentialed medical assistants” are permitted to enter medication laboratory and radiology orders into the CPOE system. Other data (financial, demographic, list of medications, patient history) can be entered by individuals other than “credentialed medical assistants.” Don

      Sent from my iPhone

      Reply

      1. Just so I am certain, our EHR vendor has set up our MAs to be credentialed through the NHA (National Healthcare Association). That will suffice, right?

        Reply

  12. All of those in our office who were ever a CMA or went to school to be an MA, but were not Certified, I set up with the NHA to test and once they passed the proctored exam, became a CCMA. Thereby allowed to qualify to have the CCMA after there name and could in fact meet the CPOE ruling under the CMS. Please remember that before 2005 those that went to school for Medical Assistant had the option whether to test or not. So I found a lot of those in the office, so they are now officially a CCMA by the NHA.

    I also taught college students to become a CMAA for the NHA. I would believe they are not okay to enter CPOE. This is a Certified Medical Administrative Assistant, and is nothing more than a glorified front desk receptionist. However, depending on how long they have held that position and what they have learned afterwards, and the duties of their job, I would read what the AAMA did below in regards to having those with the proper background test for their ABR-OE in order to meet CMS CPOE requirement.

    I would like to reply and help those whom have any questions in regards to a “Credentialed Medical Assistant”. Under the AAMA, they specifically created the ABR – OE (Assessment Based Recognition – Order Entry) for those who have never held the title of a CMA or have went to school to become a CMA. If one has ever held the credential of a CMA or is currently in school, they are not eligible for this ABR-OE credential. This allows them the opportunity to become a Credentialed Medical Assistant” in the laws of CMS. Thereby, satisfying the CPOE requirement as having the knowledge required to enter the orders. They have to test on 5 key elements which include, Anatomy & Physiology, Medical Terminology, Medical Record Errors and so forth. Please go to the AAMA website and see what it takes to test for the ABR-OE. Again, this was created by the AAMA for this very reason. The physician has to submit a letter on behalf of the individual certifying that they hold certain values and have been doing so for at least 24 months under the direct supervision of the provider as well as the provider has to submit a copy if their license for verification. By the way one holding the ABR-OE is in no way titled or allowed to have CMA after their name. It merely states they meet the requirements to do CPOE as set forth by CMS for MU, All Stages.

    But, I have a question for Don?

    If the CMA (Certified Medical Assistant), the CCMA (Certified Clinical Medical Assistant) or Credentialed Medical Assistant who holds the ABR-OE is entering the medication in to the medical record and it looks as if it is being sent by the physician via a log in as such, isn’t that being non-compliant on the physicians part by allowing one to submit and okay the medications to be sent?

    This is a big area for me as a Practice Manager or I should say former PM as it is in clear violation of what it means to run an office and be in compliant with all Federal & State Laws.

    This would also be a violation of HIPAA by the physician providing their log in to one who is not supposed to have it? Our EMR also has a way to allow CPOE by anyone, but that can be taken away via the EMR or even the one in charge of the practice by unchecking the box that it is okay for them to do such under their log in. Ex: The receptionist, medical record clerks, billing staff or anyone not performing ANY duties that a CMA would, can and should not be checked to have this privilege.

    Reply

    1. If the CMA (Certified Medical Assistant), the CCMA (Certified Clinical Medical Assistant) or Credentialed Medical Assistant who holds the ABR-OE is entering the medication in to the medical record and it looks as if it is being sent by the physician via a log in as such, isn’t that being non-compliant on the physicians part by allowing one to submit and okay the medications to be sent?

      This would also be a violation of HIPAA by the physician providing their log in to one who is not supposed to have it? Our EMR also has a way to allow CPOE by anyone, but that can be taken away via the EMR or even the one in charge of the practice by unchecking the box that it is okay for them to do such under their log in. Ex: The receptionist, medical record clerks, billing staff or anyone not performing ANY duties that a CMA would, can and should not be checked to have this privilege.

      Thank you for the above questions. Entries made by a medical assistant should not be presented as if the physician was entering the order. It could give the impression that the physician has not reviewed and approved the medication order.

      A physician providing his/her log-in to an unapproved party is not the best practice. It would not necessarily amount to a HIPAA violation. However, this does open the possibility of a violation of the CMS rule about who can enter orders into the CPOE system 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

      Reply

  13. A question about associating a diagnosis for a protocol order. Do you think a CMA can enter a diagnosis based on a protocol without the provider first initiating the protocol?

    Reply

    1. Thank you for your question. It is my legal opinion that, under the laws of all states, physicians are permitted to approve a diagnostic protocol for the medical assistant to follow in forwarding a suggested diagnosis to the overseeing/delegating/supervising provider. However, the provider must review and approve for each individual patient the suggested diagnosis based on the protocol. Then, the provider must sign the order (electronically or otherwise) and forward it, or direct the medical assistant to forward the order signed by the provider.

      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]

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  15. Do certified Medical Administrative Assistants qualify for meaningful use CPOE delegate? Ive got 16 years experience and trying to determine if I can take the administrative test. I enter radiology orders

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