I recently received the following request for information from a medical group in South Carolina:
We [need] to find out what tasks certified medical assistants can do and what uncertified medical assistants cannot do.
The South Carolina Medical Board gave us a list of tasks that certified medical assistants can do; however, [they] will not tell us [whether] uncertified medical assistants can or cannot do these tasks.
Any information you can provide is greatly appreciated.
For more information, see the 2022 South Carolina law. Note the following excerpts, particularly the bolded and italicized sections:
“(63) ‘Unlicensed assistive personnel’ or ‘UAP’ are persons not currently licensed by the board as nurses, or persons who are not certified medical assistants as defined in Section 40-33-20( ), who perform routine nursing tasks that do not require a specialized knowledge base or the judgment and skill of a licensed nurse. Nursing tasks performed by a UAP must be performed under the supervision of a physician, physician assistant, an advanced practice registered nurse, registered nurse, or selected licensed practical nurse. Unlicensed assistive personnel must not administer medications except as otherwise provided by law.”
…
SECTION 3. Section 40-33-42(C) of the 1976 Code is amended to read:
“(C) Subject to the rights of licensed physicians and dentists under state law, and except as provided in Section 40-47-196 regarding the delegation of tasks to certified medical assistants, the administration of medications is the responsibility of a licensed nurse as prescribed by the licensed physician, dentist, other authorized licensed provider or as authorized in an approved written protocol or guidelines. Unlicensed assistive personnel must not administer medications, except as otherwise provided by law.”
The medical group followed up with an additional question:
In reference to below, the South Carolina [Board of Medical Examiners] has listed the following tasks that can be delegated to a CMA (AAMA). Do you feel that an uncertified medical assistant is also able to perform these tasks? We tried to get clarification from them, but they instructed us to contact the AAMA.
- Point of Care Testing (e.g., strep test, flu swab, urine dip, etc.)
- Entering Verbal Orders
- [Preparing] and Administering Vaccines
- Administering In-Clinic Medications
- Straight Needle Blood Draw
- Performing Basic [Laboratories]
- Performing Screening Tests (ex: [ECG], vision, hearing, etc.)
- Removing Sutures and Changing Dressings
- Performing Non-Clinical Tasks via Telemedicine
- Administering Allergy Tests
- Entering Prescription Refills
- Responding to Patient Phone Calls and Messages
The listed tasks were included in documents by the South Carolina Board of Medical Examiners and the South Carolina Board of Nursing.
These documents indicate that the South Carolina Board of Nursing and the South Carolina Board of Medical Examiners are taking the legal position that only the tasks listed under “authorized tasks that can be delegated to certified medical assistants with appropriate training” are delegable legally to CMAs (AAMA) and only CMAs (AAMA). The tasks in the list may not be delegated to UAP. The Board of Nursing document states that specifically at the bottom of the second page.
To restate, the tasks included in the “authorized tasks” list may not be delegated to unlicensed medical assistants who are part of the UAP category, according to the South Carolina Board of Nursing and the Board of Medical Examiners.
Because both these state boards have issued their respective documents, I have no authority to override their opinions.
Legal Eye 