CMS Final Rule Reaffirms Credentialing Requirement for Medical Assistants

On October 6, 2015, the Centers for Medicare and Medicaid Services (CMS) issued its final rule for the Electronic Health Record (EHR) Incentive Programs. In responding to comments urging that the “credentialed medical assistant” requirement be made less stringent, CMS reaffirmed that medical assistants must have a third-party credential (such as the CMA (AAMA)), and must have sufficient knowledge to handle properly clinical decision support (CDS) alerts.

One party commenting on the CMS notice of proposed rulemaking for the EHR Incentive Programs made the suggestion “that if a standard for medical assistant CPOE [computerized provider order entry] is required, then the standard should be that the medical assistant must be appropriately trained for CEHRT [certified electronic health record technology] use (including CPOE) by the employer or CEHRT vendor in order to be counted [toward meeting the meaningful use requirements of the Incentive Programs].” (page 322 of the attached document)

CMS responded as follows:

We [CMS] disagree that the training on the use of CEHRT is adequate for the purposes of entering an order under CPOE and executing any relevant action related to a CDS. We believe CPOE and CDS duties should be considered clinical in nature, not clerical.  Therefore, CPOE and CDS duties, as noted, should be viewed in the same category as any other clinical task, which may only be performed by a qualified medical or clinical staff. (page 323 of the attached document)

This position of CMS is a resounding affirmation of the fact that only professionally-credentialed medical assistants (such as CMAs (AAMA)) are qualified to enter orders safely into the CPOE system.

More information about the CMS final rule will be forthcoming in Legal Eye: On Medical Assisting and CMA Today.

CMS Final Rule (10/6/15), pages 322-323

CMS NPRM Expands Category of Radiology Orders, Thresholds

As a follow-up to my post yesterday, the March 20, 2015, Centers for Medicare and Medicaid (CMS) notice of proposed rulemaking (NPRM) for Stage 3 of the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs has expanded the category of radiology orders to include diagnostic imaging other than radiology.  Also, the thresholds for medication, laboratory, and diagnostic imaging orders have been increased for Stage 3.  Note the following excerpts from the CMS NPRM:

We propose to continue our policy from the Stage 2 final rule that the orders to be included in this objective are medication, laboratory, and radiology orders, as such orders are commonly included in CPOE implementation and offer opportunity to maximize efficiencies for providers. However, for Stage 3, we are proposing to expand the objective to include diagnostic imaging, which is a broader category including other imaging tests such as ultrasound, magnetic resonance, and computed tomography in addition to traditional radiology. This change addresses the needs of specialists and allows for a wider variety of clinical orders relevant to particular specialists to be included for purposes of measurement.

Based on our review of attestation data from Stages 1 and 2 demonstrating provider performance on the CPOE measures, we propose to increase the threshold for medication orders to 80 percent and to increase the threshold for diagnostic imaging orders and laboratory orders to 60 percent.