Scope of Practice

New Jersey Prescription Monitoring Program: Medical Assistants as Delegates

Does New Jersey allow medical assisting access to the state prescription drug monitoring program?

Medical assistants are recognized as “delegates” under the New Jersey Prescription Monitoring Program (NJPMP). Because I have not written previously about these programs, I will explain in detail.

Note the following from the NJPMP frequently asked questions webpage:

The New Jersey Prescription Monitoring Program (NJPMP) is an important component of the New Jersey Division of Consumer Affairs’ (Division) effort to halt the abuse and diversion of prescription drugs.

The NJPMP … is a statewide database that collects prescription data on Controlled Dangerous Substances (CDS), Human Growth Hormone (HGH) and gabapentin dispensed in outpatient settings in New Jersey, and by out-of-State pharmacies dispensing into New Jersey.

Access to the NJPMP is granted to prescribers and pharmacists who are licensed by the State of New Jersey and are in good standing with their respective licensing boards. Registered prescribers may delegate their authority to access the NJPMP to certain other healthcare professionals.

Patient information in the NJPMP is intended to help prescribers and pharmacists provide better-informed patient care. The information will help supplement patient evaluations, confirm patient drug histories, and document compliance with therapeutic regimens. When prescribers, delegates, or pharmacists identify a patient as potentially having an issue of concern regarding drug use, they are encouraged to help the patient locate assistance and take any other action the prescriber or pharmacist deems appropriate.

Medical assistants who (a) meet the education requirements of New Jersey law and (b) hold a current medical assisting credential from a certifying body approved by the New Jersey State Board of Medical Examiners are authorized to be appointed as “delegates” by practitioners.

A “practitioner” is defined as an individual “currently licensed, registered, or otherwise authorized by this State or another state to prescribe drugs in the course of professional practice,” according to the administrative rules governing the NJPMP. A practitioner may “designate a delegate or delegates for the purpose of accessing PMP [prescription monitoring program] information for a new or current patient, or a prescriber.”

The NJPMP requires a “mandatory look-up” in certain situations. Note the following excerpt from the administrative rules governing the NJPMP:

a) … [A] practitioner or the practitioner’s delegate shall access prescription monitoring information for a new or current patient consistent with the following:

1) The first time the practitioner prescribes a Schedule II controlled dangerous substance or any opioid to a new or current patient for acute or chronic pain; …

2) The first time the practitioner prescribes a benzodiazepine drug that is a Schedule III or Schedule IV controlled dangerous substance;

3) If the practitioner has a reasonable belief that the person may be seeking a controlled dangerous substance, in whole or in part, for any purpose other than the treatment of an existing medical condition, such as for purposes of misuse, abuse, or diversion, the first time the practitioner or other person prescribes a non-opioid drug other than a benzodiazepine drug that is a Schedule III or Schedule IV controlled dangerous substance;

4) Any time the practitioner prescribes a Schedule II controlled dangerous substance for acute or chronic pain to a patient receiving care or treatment in the emergency department of a general hospital;

5) On a quarterly basis during the period of time a current patient continues to receive a prescription for a Schedule II controlled dangerous substance or for an opioid drug for acute or chronic pain, or for a benzodiazepine that is a Schedule III or Schedule IV controlled dangerous substance.

Each provider must establish written processes to document in each patient’s record the information obtained from the prescription monitoring program. The disclosure of prescription monitoring program information is determined by state and federal law.

Certification and the CMA (AAMA) Credential

Who Can Take the CMA (AAMA)® Exam?

Q. Who is eligible to take the CMA (AAMA)® Certification Exam?

A. The only individuals eligible to take the CMA (AAMA) Certification Exam and become CMAs (AAMA) are graduates or graduating students of medical assisting programs that fall within one of the following categories:

  • Accredited by the Commission on Accreditation of Allied Health Education Programs (CAAHEP)
  • Accredited by the Accrediting Bureau of Health Education Schools (ABHES)
  • Meets the criteria for the time-limited Certification Exam Eligibility Pilot Program

The Certification Exam Eligibility Pilot Program is a three-year pilot program, begun August 2019, that allows graduates of postsecondary (college-level) medical assisting programs to take the CMA (AAMA) Exam if the program meets certain requirements, including the program being part of an institution accredited by an accrediting body recognized by either the United States Department of Education (USDE) or the Council for Higher Education Accreditation (CHEA).

Hopeful exam candidates can gather all required documentation and submit their documentation for review—to see if they are eligible under the pilot program—for free online via the AAMA website.

Certification and the CMA (AAMA) Credential

The CMA (AAMA)® Certification Exam Eligibility Pilot Program

The Certifying Board (CB) of the American Association of Medical Assistants® (AAMA) has approved the launch of a three-year eligibility pilot program, which temporarily opens a new education pathway for medical assistants to become eligible to sit for the CMA (AAMA)® Certification Exam.

Applicants first submit their documentation for review, free of charge, to determine their eligibility to apply for the exam. The criteria and submission requirements for the review are outlined on the Eligibility Pilot Program webpage of the AAMA website.

Before implementing the program, the CB took into account several policy priorities, including but not limited to the following:

  • Maintaining global and national accreditation standards
  • Heeding a recommendation from the National Commission for Certifying Agencies
  • Needing to collect and evaluate empirical evidence on examination performance by candidates who are not graduates of accredited medical assisting programs

Examine all the CB’s considerations and rationale in detail by reading the November/December 2019 Public Affairs article, “The CMA (AAMA)® Certification Exam Eligibility Pilot Program: Criteria and Rationale for the Three-Year Pilot Study,” on the AAMA website.

Certification and the CMA (AAMA) Credential, On the Job, Professional Identity

“Certified Medical Assistant” vs. “Medical Assistant-Certified” in Washington: A Review of Permissible Usage among Programs

The distinction between “certified medical assistant” and its variations can be difficult for medical assisting programs to make. Trademark registrations and state law need to be taken into consideration.

Take this question for example:

Can a Washington-based medical assisting program that meets the requirements of the Washington State Department of Health (e.g., graduates can become a “medical assistant-certified” [MA-C]) but not the CMA (AAMA)® Certification Exam use the phrase “certified medical assistant” in connection with their program?

The American Association of Medical Assistants® (AAMA) holds a trademark registration with the U.S. Patent and Trademark Office for the phrase “certified medical assistant.” Any party’s use of the phrase that is likely to confuse or mislead the public is an infringement of the AAMA’s intellectual property rights in the phrase.

Medical assisting programs that are not accredited by either the Commission on Accreditation of Allied Health Education Programs (CAAHEP) or the Accrediting Bureau of Health Education Schools (ABHES) should not use the phrase because it could be misconstrued as their graduates being eligible for the CMA (AAMA) Certification Exam.

Washington State Legislature has established several categories for medical assistants (WAC 246-827-0010), but the medical assistant-certified (MA-C) category is the one most likely to be confused with “certified medical assistant” permissible usage. Note the requirements for becoming an MA-C:

WAC 246-827-0200

Medical assistant-certified—Training and examination.

An applicant for a medical assistant-certified credential must meet the following requirements:

(1) Successful completion of one of the following medical assistant training programs:

(a) Postsecondary school or college program accredited by the Accrediting Bureau of Health Education Schools (ABHES) or the Commission of [sic] Accreditation of Allied Health Education Programs (CAAHEP);

(b) Postsecondary school or college accredited by a regional or national accrediting organization recognized by the U.S. Department of Education, which includes a minimum of seven hundred twenty clock hours of training in medical assisting skills, including a clinical externship of no less than one hundred sixty hours;

(c) A registered apprenticeship program administered by a department of the state of Washington unless the secretary determines that the apprenticeship program training or experience is not substantially equivalent to the standards of this state. The apprenticeship program shall ensure a participant who successfully completes the program is eligible to take one or more examinations identified in subsection (2) of this section; or

(d) The secretary may approve an applicant who submits documentation that he or she completed postsecondary education with a minimum of seven hundred twenty clock hours of training in medical assisting skills. The documentation must include proof of training in all of the duties identified in RCW [Revised Code of Washington] 18.360.050(1) and a clinical externship of no less than one hundred sixty hours.

(2) Pass a medical assistant certification examination, approved by the secretary, within five years of submitting an initial application. A medical assistant certification examination approved by the secretary means an examination that:

(a) Is offered by a medical assistant program that is accredited by the National Commission for Certifying Agencies (NCCA); and

(b) Covers the clinical and administrative duties under RCW 18.360.050(1).

Consequently, if the medical assisting program meets (1)(a), (b), (c), or (d), it would be permissible for the program to state that graduates meet the educational portion of the MA-C requirements. It would also be permissible to state that graduates would be eligible for one or more of the NCCA-accredited medical assisting certification programs.

For more information on whether a Washington-based MA-C can write “CMA” after their name, see my blog post “Can Washington State Medical Assistants Use the ‘CMA’ Initialism?

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.