The Centers for Medicare and Medicaid Services (CMS) recently issued an important clarification regarding meaningful use order entry. See the following quote from a report by the American Academy of Ophthalmologists:
EHR Meaningful Use Update: CMS Comes Out Against Scribes
Despite Academy efforts, the Centers for Medicare & Medicaid Services clarified this week that medical scribes − even those who are certified − are not permitted to enter electronic medication, laboratory, or radiology orders into electronic health record systems. The Academy believes that changes to the criteria for satisfying the EHR Meaningful Use Program’s Computerized Provider Order Entry measure lacked clarity regarding appropriate personnel who may perform this task.
In communication to the Academy, CMS explained that it is not permitting scribes to enter medical data under the CPOE measure. Medical staff entering orders into EHRs for purposes of satisfying the CPOE measure must be, at minimum, a certified medical assistant or equivalent, which includes certified ophthalmic technicians, certified ophthalmic technologists, and certified ophthalmic assistants.
Questions have arisen about the 60-month-after-graduation requirement for the CMA (AAMA) Certification Examination, and eligibility to recertify by retesting.
- Individuals who have graduated from a medical assisting program accredited by the Commission on Accreditation of Allied Health Education Programs (CAAHEP) or the Accrediting Bureau of Health Education Schools (ABHES) on or after January 1, 2010, must take and pass the CMA (AAMA) Certification Examination within 60 months after the date of graduation. Individuals who graduated before January 1, 2010, are not subject to the 60-month requirement. In other words, according to current policy of the Certifying Board of the AAMA, an individual who graduated from a CAAHEP or ABHES accredited medical assisting program prior to January 1, 2010, is not subject to any time limit for taking and passing the CMA (AAMA) Certification Examination and being awarded the CMA (AAMA) credential.
- Prior to the June, 1998 administration of the CMA (AAMA) Certification Examination, there were eligibility pathways other than graduation from a CAAHEP or ABHES accredited medical assisting program. Generally, those who became CMAs (AAMA) prior to June of 1998 and were not graduates of an accredited program are eligible to recertify by continuing education or retesting. Such individuals are not forbidden from recertifying by retesting because they did not graduate from a CAAHEP or ABHES accredited program.
As the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs continue to be implemented and enforced, questions arise about how certain objectives for meaningful use affect reimbursement. The short answer to these questions is that all objectives are critical. Failure to meet even one objective for meaningful use can result in not only a payment forfeiture, but also retroactive recoupment of previous payments, as well. Thus, it is incumbent on all health care providers to ensure that proper steps are being taken to comply with all meaningful use objectives. The text and video of Mr. Anthony’s statement on this matter follows:
“That’s correct. If [a practice] is not meeting all of the objectives for meaningful use for a program year, then that payment would be forfeit. … As we move forward, of course, every year is going to be a deciding year for payment adjustments—so potentially, if an audit comes through and you forfeit a payment, you may not only be forfeiting the payment, but you would also be subject retroactively to payment adjustments, as well.”
In the continuing discussion about computerized provider order entry (CPOE), a frequent question concerns whether a noncredentialed health care professional could circumvent any safeguards and perform order entry into an electronic health record (EHR) system. As Rob Antony of CMS stated last year, it is indeed possible to do this. However, that possibility is one of the primary reasons for CMS audits, which could identify and penalize such behaviors. A standard EHR system would maintain a log of which staff members enter orders. Any practice found violating the requirements for order entry could be subject to financial penalties. The full text and video of Mr. Anthony’s statement follows:
“There’s not a requirement as part of certification that your certified EHR has to identify you as [a] credentialed [medical assistant]; there’s actually not a requirement within certification that you have to be identified as anything. However, for purposes of entry, for purposes of workflow, the [eligible professional] and the practice [have] to make sure that’s who is entering that information. We realize that not every EHR may have that information, but certainly a large number of them do, and I can anticipate that an auditor would ask for that log.”
“We don’t actually have any additional regulatory authority beyond what we have with incentive payments and payment adjustments, specific to this program for CPOE. It is possible for anyone to game the system here. That’s why an auditor might look at credentialing and would look at those audit logs to see whether or not that was likely to have happened. The authority here, or the clout, Is either if an auditor goes through and discovers that people were erroneously counted within a numerator and you did not actually meet meaningful use, you would forfeit an incentive payment, and then potentially [it would] be applied [to] the payment adjustments. So certainly if an auditor comes by afterward and discovered that your attestation was not correct, then it would be a forfeit of payment or a recoup of payment, and potentially things that are egregious fraud get sent for additional prosecution.”
Posted in Certification and the CMA (AAMA) Credential, On the Job, Professional Identity, Scope of Practice
Tagged Centers for Medicare and Medicaid Services, CMA (AAMA), CMS Rule, CMS Stage 2 Rule, computerized provider order entry, CPOE system, credentialed medical assistants, EHR incentive programs, electronic healthcare records, meaningful use
We have detailed who can perform computerized provider order entry (CPOE) for meaningful use objectives, as well as the potential costs of improper CPOE. Naturally, the broader question in this discussion is why only licensed health care professionals or credentialed medical assistants are allowed to perform CPOE.
These rulings are made with patient protection as the primary goal. One way the limits on CPOE help ensure that protection involves a function of the CPOE system known as clinical decision support alerts.
Robert Anthony of the Centers for Medicare and Medicaid Services spoke about these alerts and their importance for patient safety in his presentation. The full text and video are below:
“The purpose of this really is to make sure that when information goes into a system, and it is done obviously prior to any action being taken on the orders … that somebody who has some clinical expertise or authority is able to see any of the clinical decision support alerts that pop up and say, ‘You may not want to prescribe this medication because of a contraindication.’ Then they can take action on that for patient safety, whereas I as a lay person might see a clinical decision alert, have no idea what that means, and ignore it completely. So that’s really the whole idea behind having a licensed health professional or a CMA (AAMA) to look at that.”