Centers for Medicare & Medicaid Services, delegation, On the Job, Professional Identity

Appropriate Use Criteria Program: CMAs (AAMA)® Meet Clinical Staff Criteria under the CMS Rule

In the Public Affairs article of the March/April 2018 CMA Today, I argued that “appropriately educated and credentialed medical assistants” such as CMAs (AAMA)® are clinical staff under the Medicare Chronic Care Management (CCM) and Transitional Care Management (TCM) programs.

I now add that CMAs (AAMA) are also clinical staff according to the Centers for Medicare & Medicaid Services (CMS) rule regarding the appropriate use criteria (AUC) program. Therefore, as a result of their clinical staff status, I assert that CMAs (AAMA) are permitted to do the following:

  1. Consult a clinical decision support mechanism (CDSM) about the appropriateness of ordering a particular advanced diagnostic imaging service
  2. Report findings to their overseeing or delegating licensed providers

Review the supporting evidence in the September/October 2019 Public Affairs article, “Appropriate Use Criteria Program,” on the AAMA website.

On the Job, Professional Identity

Permissible Initialisms for Student Medical Assistants

It is legally inadvisable for student medical assistants who are on their externship/practicum to include any unrecognized initialism, such as the initials “SMA” (for “Student Medical Assistant”), after their names. Because “SMA” is not a recognized credential for medical assistants and there is no recognized credential given to medical assisting students just for being a student, externing students who insert any initialism after their names could cause confusion.

Using an unrecognized credential is an important issue for the medical assisting profession because of the large number of credentials and initialisms that currently exist in medical assisting.

If a practicum site strongly prefers that the externing medical assisting students identify themselves in some distinctive way, it would be preferable to have the students use the phrase “Student Med Asst” or some other type of designation.

delegation, On the Job, Scope of Practice

Medical Assistants and Fetal Nonstress Test Monitors

State laws are the best place to look for guidance on medical assisting scope of practice, but they are sometimes less thorough than desired. For cases such as those, consider the following:

We have some CMAs (AAMA) and RMAs(AMT) assisting physicians who are providing obstetrical services. The physicians delegate to the medical assistants the hooking up of patients to fetal nonstress test monitors. The medical assistants do not interpret the results of the fetal nonstress test. Is this delegation permitted by Minnesota law?

Based on my research, hooking up a patient to a fetal nonstress test monitor is a straightforward, repeatable process that does not require (1) the knowledge or skill or a licensed health care professional, (2) the exercise of independent clinical judgment, or (3) the making of clinical assessments. Therefore, my legal opinion is that this task is likely delegable to knowledgeable and competent unlicensed allied health professionals such as medical assistants working under direct/onsite physician supervision.

The delegating physicians should reverify periodically (perhaps every 12 months) the knowledge and skill of the medical assistants performing this task and should document in writing each medical assistant’s current competence in this task.

It may also be advisable to request a written opinion from the practice’s malpractice insurance carrier stating that it would cover any negligence by a medical assistant in hooking up a patient to a fetal nonstress test monitor.

On the Job

The Role of Medical Assistants in Increasing Colorectal Cancer Screening Rates

On April 16, 2019, I presented a webinar for the Illinois Primary Health Care Association to illustrate that the utilization of knowledgeable and competent medical assistants, especially CMAs (AAMA), across health care settings significantly increases colorectal cancer (CRC) screening rates.

Review the supporting evidence in the July/August 2019 Public Affairs article, “The Role of Medical Assistants in Increasing Colorectal Cancer Screening Rates,” on the AAMA website.

delegation, On the Job, Scope of Practice

Relaying Providers’ Orders by Telephone

Part of the AAMA’s mission is to protect medical assistants’ scope of practice. Sometimes that means gathering evidence to prove that what other health professionals think is a limitation of medical assistants’ scope of practice is unsubstantiated by state law. Consider the following from a medical assistant in Wisconsin:

I work in a small physician-owned clinic. Our primary care providers visit two local skilled nursing facilities each month. … [Does] our state permit nurses to take a provider’s order by telephone that is conveyed by a medical assistant? These telephone orders are always followed up by a written electronic order from the provider. [But] we are being told that nursing home staff will only take telephone orders directly from licensed health professionals.

Why would this be any different from a provider directing one of our medical assistants to convey a normal lab value? Our providers would spend all day calling the nursing homes if medical assistants cannot relay information at the request of the provider. If the nursing home staff members do not understand the order, they can always ask for clarification from one of our providers.

I reviewed the nurse practice act and the regulations and policies of Wisconsin’s state board of nursing. I found nothing stating that registered nurses (RNs) and licensed practical nurses (LPNs) are prohibited from receiving and executing orders from a licensed provider (e.g., physicians, nurse practitioners, physician assistants) that are transmitted verbatim by telephone by an unlicensed allied health professional, such as a medical assistant.

Unless state law specifically indicates otherwise, my legal opinion is that knowledgeable and competent medical assistants are permitted to convey verbatim information (including orders) on behalf of the delegating provider and receive verbatim information for the overseeing provider. Information conveyed by telephone should be followed up by a written order (electronic or hard copy).