Centers for Medicare & Medicaid Services, CMS Rule, Scope of Practice

Testing Period Extension for the AUC Program

Note the recent update via the Centers for Medicare & Medicaid Services on the appropriate use criteria (AUC) program:

NOTICE: The EDUCATIONAL AND OPERATIONS TESTING PERIOD for the AUC Program has been extended through CY 2021. There are no payment consequences associated with the AUC program during CY 2020 and CY 2021. We encourage stakeholders to use this period to learn, test and prepare for the AUC program.

The following describes the intended AUC program timeline, according to the Centers for Medicare & Medicaid Services:

Program Timeline

Currently, the program is set to be fully implemented on January 1, 2022 which means AUC consultations with qualified CDSMs [clinical decision support mechanism] are required to occur along with reporting of consultation information on the furnishing professional and furnishing facility claim for the advanced diagnostic imaging service. Claims that fail to append this information will not be paid. Prior to this date the program will operate in an Education and Operations Testing Period starting January 1, 2020 during which claims will not be denied for failing to include proper AUC consultation information. Beginning July 1, 2018 the program is operating under a voluntary participation period during which time consultations with AUC may occur and may be reported on furnishing professional and facility claims using HCPCS [Healthcare Common Procedure Coding System] modifier QQ.

As a reminder, I provide supporting evidence for my position that CMAs (AAMA) are clinical staff according to the Centers for Medicare & Medicaid Services rule regarding the AUC program in my Public Affairs article of the September/October 2019 CMA Today. 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

Find the article, as well as all my other Public Affairs articles, on the AAMA website.

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?

Accreditation, Certification and the CMA (AAMA) Credential

Medical Assisting Programs Should Maintain Programmatic Accreditation

Since the announcement of the CMA (AAMA)® Certification Exam Eligibility Pilot Program, many people have had questions concerning its rationale and ramifications. Take the following set of questions for example:

This new pilot program has North Carolina educators in deep discussion. I wanted to clarify a few items before presenting this new pilot program to my advisory board:

  1. What is the benefit of programs to maintain accreditation if students can sit for the CMA (AAMA) Certification Exam in a nonaccredited program?
  2. When students find out about this pilot program, retention rates could be affected. Is the AAMA prepared to address this issue? I can imagine that curriculum revisions will be increasing. Our college administration has insisted that we offer a one-year diploma that is not accredited to offer students the opportunity to complete faster. 
  3. Is the pilot program expected to be available for three years?

Those are great questions. Medical assisting programs accredited by the Commission on Accreditation of Allied Health Education Programs (CAAHEP) or the Accrediting Bureau of Health Education Schools (ABHES) should maintain their programmatic accreditation because state boards of medical examiners and state boards of nursing have established education and/or credentialing requirements for medical assistants who are delegated the administration of medication by physicians, physician assistants, and advanced practice registered nurses (APRNs), especially nurse practitioners.

Note the following requirements for medical assistants to be registered, and therefore permitted to work as medical assistants, from the joint rules of the South Dakota Board of Nursing and the South Dakota Board of Medical and Osteopathic Examiners:

20:84:04:01. Approved education programs. An applicant for registration shall have graduated from a medical assistant program that is approved by the boards or accredited by the Commission on Accreditation of Allied Health Education Programs (CAAHEP), or a similar accrediting institution approved by the United States Department of Education. Approved programs must provide classroom, laboratory, and clinical learning experiences that provide for student attainment of entry-level competence as a registered medical assistant.

The number of CAAHEP- and ABHES-accredited medical assisting programs—and the number of their graduates—has decreased in the last five years. Some programs have closed, and some continue to offer a medical assisting program but have discontinued their programmatic accreditation.

However, anecdotal evidence is emerging that accredited medical assisting programs that have articulation agreements with other allied health programs are experiencing stable if not increasing enrollment in their medical assisting programs.

And yes, the CMA (AAMA) Certification Exam Eligibility Pilot Program will be available for three years, which began in August 2019. For more information, visit the Eligibility Pilot Program webpage on the AAMA website.