Massachusetts Law Outlines Delegation of Immunizations

In 2016 the Massachusetts legislature passed legislation that permits primary care providers to delegate the administration of immunizations to a medical assistant who is the following:

…is a graduate of a post-secondary medical assisting education program accredited by the Committee on Allied Health Education and Accreditation of the American Medical Association, or its successor, the Accrediting Bureau of Health Education Schools, or its successor or such other certificate program as the commissioner of public health shall approve; (ii) is employed in the medical practice of a licensed primary care provider; and (iii) who performs basic administrative, clerical, and clinical duties upon the specific authorization and under the direct supervision of a licensed primary care provider.

Note the following definitions from the legislation:

Direct supervision: “Oversight of a certified medical assistant exercised by a primary care provider who is present in the facility and immediately available to furnish assistance and direction throughout the course of the performance of a delegated procedure but is not required to be present in the room when the procedure is being performed.”

Primary care provider: “A health care professional qualified to provide general medical care for common health care problems who: (i) supervises, coordinates, prescribes, or otherwise provides or proposes health care services; (ii) initiates referrals for specialist care; and (iii) maintains continuity of care within the scope of practice.”

The legislation directs the Massachusetts Department of Public Health to promulgate regulations regarding the specifics of the delegation of immunizations. The full text of the legislation can be found on the AAMA website, under State Scope of Practice Laws.

Posted in delegation, medication administration, On the Job, Scope of Practice | Tagged , , , , , | 2 Comments

Congressional Action on the ACA

As our government transitions to a new administration, the following question has become increasingly common:

Would amendments to or repeal of the Affordable Care Act (ACA) affect medical assistants’ scope of practice?

The answer? Almost certainly not.  The scope of practice of medical assistants is determined primarily by state law.  An exception is the meaningful use order entry requirements of the Medicaid Electronic Health Record Incentive Program.  The Medicaid Incentive Program was not created by the ACA and would not be impacted by any amendments to or repeal of the Affordable Care Act.  Consequently, it is highly unlikely that the scope of practice for medical assistants will be impacted by congressional action on the ACA.

Posted in Affordable Care Act (ACA), EHR Incentive Programs, Meaningful Use, Medicaid, Medicare, Scope of Practice | Tagged , , , , , | Leave a comment

MACRA and Order Entry Requirements

The Medicare Access and CHIP (Children’s Health Insurance Program) Reauthorization Act of 2015 (MACRA) mandated that the Medicare Electronic Health Record (EHR) Incentive Program come to an end on December 31, 2016. One of the new payment mechanisms for Medicare established by MACRA is the Merit-Based Incentive Payment System (MIPS). Under the primary reporting method of MIPS, an eligible provider is not required to report to the Centers for Medicare & Medicaid Services (CMS) that medication, laboratory, and diagnostic imaging orders are being entered by credentialed medical assistants or licensed health care professionals.

CMS, however, offers eligible providers an alternate reporting method under MIPS. Under this method, providers are permitted to report on optional measures, such as computerized provide order entry (CPOE).

This issue will be addressed in greater detail in the upcoming January/February 2017 issue of CMA Today. In the meantime, all past Public Affairs articles by CEO Balasa can be found on the AAMA website

Posted in Centers for Medicare & Medicaid Services, Computerized Provider Order Entry (CPOE), EHR Incentive Programs, On the Job | Tagged , , , , , , , | 9 Comments

Physician Delegation: Standing Orders

Under the laws of most states, physicians are permitted to delegate by means of standing orders to knowledgeable and competent medical assistants as long as the following conditions are met:

  1. The standing order is understood by the medical assistant
  2. The standing order is for a task that is delegable to medical assistants under the laws of the state, and the delegating physician is exercising the degree of supervision required by the laws of the state
  3. The standing order is applicable to all patients without exception
  4. The standing order does not require the medical assistant to exercise independent professional judgment, or to make clinical assessments, evaluations, or interpretations
Posted in delegation, On the Job, Scope of Practice, Uncategorized | Tagged , | 10 Comments

Order Entry Requirements for Non-Physician Practitioners

I was recently asked whether non-physician practitioners (e.g., nurse practitioners and physician assistants) must meet the meaningful use order entry requirements under the Medicaid Electronic Health Record (EHR) Incentive Program.  The answer is yes.

The following are considered “eligible professionals” (EPs) who can participate in the  Medicaid EHR Incentive Program:

  • Physicians (primarily doctors of medicine and doctors of osteopathy)
  • Nurse practitioners
  • Certified nurse-midwives
  • Dentists
  • Physician assistants who furnish services in a Federally Qualified Health Center or Rural Health Clinic that is led by a physician assistant

All participating EPs must meet the computerized provider order entry (CPOE) requirements of the Incentive Program in order to receive incentive payments.

Posted in Computerized Provider Order Entry (CPOE), EHR Incentive Programs, Eligible Professionals, Medicaid, On the Job | Tagged , , , , , | Leave a comment