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.
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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].
I have been receiving questions about whether a medical assistant who formerly held the CMA (AAMA) credential is considered by the Centers for Medicare and Medicaid Services (CMS) to be a “credentialed medical assistant,” and is permitted to enter medication, laboratory, and radiology orders into the computerized provider order entry (CPOE) system for “meaningful use” calculations under the Medicare and Medicaid Electronic Health Records Incentive Programs.
First of all, it is important to understand that the policy of the Certifying Board of the AAMA states that only a current CMA (AAMA) is permitted legally to use the initialisms “CMA” or “CMA (AAMA),” and the phrases “Certified Medical Assistant” or “certified medical assistant.” Anyone other than a current CMA (AAMA) who does so is violating the intellectual property rights of the American Association of Medical Assistants.
Because an individual whose CMA (AAMA) is not current cannot use the credential for any purpose, such an individual is not a “credentialed medical assistant” according to the CMS rule, and cannot enter orders into the CPOE system and have such entry count toward meeting the meaningful use requirements. The individual must recertify and make current the CMA (AAMA) credential in order to meet the CMS definition of a “credentialed medical assistant.”
On March 19 the Public Health Committee of the Connecticut legislature held a public hearing on General Assembly Raised Bill No. 459, “An Act Concerning Medical Assistants.” This legislation was the result of a scope of practice request submitted by the American Association of Medical Assistants and the Connecticut Society of Medical Assistants (CSMA) on July 16, 2012, to the Connecticut Department of Public Health (as described in the March/April 2013 issue of CMA Today).
Raised Bill No. 459 would permit physicians to delegate to medical assistants who had graduated from an accredited postsecondary medical assisting program and who are certified by the Certifying Board of the AAMA “the administration of medication orally, by inhalation, or by intramuscular, intradermal, or subcutaneous injections, including, but not limited to, the administration of a vaccine.” The bill would also require that the medication be administered “under the direct supervision, control, and responsibility of a physician who is in the outpatient clinic or office when such medication is administered.”
The AAMA and the CSMA submitted joint written testimony in support of Raised Bill No. 459, and Holly Martin, CMA (AAMA), of the CSMA, presented oral testimony at the March 19 hearing. Legal Eye will keep readers informed about the outcome of Bill No. 459.
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.
Effective at the beginning of 2014, the AAMA has established an Assessment-Based Recognition (ABR) in order entry program for electronic health records (EHRs). Individuals who are granted this ABR in order entry meet the “credentialed medical assistant” requirement under the September 5, 2012, rule of the Centers for Medicare and Medicaid Services (CMS) of the Medicare and Medicaid EHR Incentive Programs.
I wrote a question-and-answer piece on this matter in the January/February 2014 issue of CMA Today, and would like to highlight a few points from that article.
First and foremost, the creation of the ABR in order entry in no way undermines the AAMA’s commitment to the CMA (AAMA) credential. The association maintains the position that the CMA (AAMA) is an unmatched way of demonstrating the knowledge and competency required by the medical assisting profession.
When the CMS ruling took effect on January 1, 2013, many working medical assistants had not graduated from a CAAHEP or ABHES accredited medical assisting program, and were thus not eligible to sit for the CMA (AAMA) Certification Examination. In effect, they had no way of meeting the CMS requirement through the AAMA. The Board of Trustees, as leaders of not only the association but also the profession, realized the necessity of providing these medical assistants with a way to demonstrate the knowledge sufficient to meet the CMS requirement. The ABR in order entry program provides that pathway.
The full text of my article can be found on the AAMA website.