New AAMA Initiative Urges Private Payers to Adopt CMS Order Entry Requirements

The Medicaid Promoting Interoperability Program (formerly the Medicaid Electronic Health Record Incentive Program) will be ending December 31, 2021, because of the provisions of the 2009 Health Information Technology for Economic and Clinical Health (HITECH) Act and the regulations of the Centers for Medicare & Medicaid Services (CMS). One notable requirement of the Medicaid Promoting Interoperability Program for participating licensed providers to receive an annual incentive payment is that they must attest that at least 60% of medication, 60% of laboratory, and 60% of diagnostic imaging orders have been entered into the computerized provider order entry (CPOE) system by either credentialed medical assistants or licensed health care professionals. 

Effective immediately, the Board of Trustees of the American Association of Medical Assistants® (AAMA) has authorized the AAMA to embark upon a nationwide initiative to persuade third-party payers to include the 60% order entry personnel provision in its reimbursement requirements. 

Further information will be forthcoming.

Medical Assistants’ Competence in Performing Diagnostic Tests: Comments to CMS

On August 14, 2020, I submitted comments to the Centers for Medicare & Medicaid Services (CMS) of the Department of Health and Human Services regarding proposed rule CMS-1734-P.

Read those comments in the September/October 2020 Public Affairs article, “Medical Assistants’ Competence in Performing Diagnostic Tests: Comments to the CMS,” on the AAMA website.

Conditions of Participation and Medical Assisting

The Centers for Medicare & Medicaid Services (CMS) Conditions of Participation (CoPs) do not preempt or override state scope of practice laws. Moreover, state laws regarding provider delegation to medical assistants are not altered or nullified when medical offices and clinics are owned, operated, or on the premises of a hospital that is required to meet CMS CoPs.

Review the supporting evidence in the March/April 2019 Public Affairs article, “Conditions of Participation,” on the AAMA website.

Eligible Professionals in the Medicaid EHR Incentive Program

I would like to note the recent update on eligible professionals (EPs) from the Centers for Medicare & Medicaid Services:

EPs that attest directly to a state for that state’s Medicaid EHR Incentive Program will continue to attest to the measures and objectives finalized in the 2015 EHR Incentive Programs Final Rule (80 FR 62762 through 62955). In 2017, Medicaid EPs have the option to report to the Modified Stage 2 or Stage 3 objectives and measures.

As a reminder, the following are considered to be EPs under the Medicaid Incentive Program:

• Doctors of medicine
• Doctors of osteopathy
• Doctors of dental medicine or surgery
• Nurse practitioners
• Certified nurse midwives
• Physician assistants (PAs) when working at a federally qualified health center or rural health clinic that is so led by a PA

Finally, please note the following language from the 2015 final rule, which is referred to in the previous block quote and is attached at the end of this post:

We are adopting the objective for EPs, eligible hospitals and CAHs [critical access hospitals] as follows:

Objective 4: Computerized Provider Order Entry

Objective: Use computerized provider order entry (CPOE) for medication, laboratory, and diagnostic imaging orders directly entered by any licensed healthcare professional, credentialed medical assistant, or a medical staff member credentialed to and performing the equivalent duties of a credentialed medical assistant, who can enter orders into the medical record per state, local, and professional guidelines.

Measure 1: More than 60 percent of medication orders created by the EP or authorized providers of the eligible hospital or CAH inpatient or emergency department (POS 21 or 23) during the EHR reporting period are recorded using computerized provider order entry;

• Denominator: Number of medication orders created by the EP or authorized providers in the eligible hospital or CAH inpatient or emergency department (POS 21 or 23) during the EHR reporting period.
• Numerator: The number of orders in the denominator recorded using CPOE.
• Threshold: The resulting percentage must be more than 60 percent in order for an EP, eligible hospital, or CAH to meet this measure.
• Exclusion: Any EP who writes fewer than 100 medication orders during the EHR reporting period.

Measure 2: More than 60 percent of laboratory orders created by the EP or authorized providers of the eligible hospital or CAH inpatient or emergency department (POS 21 or 23) during the EHR reporting period are recorded using computerized provider order entry; and

• Denominator: Number of laboratory orders created by the EP or authorized providers in the eligible hospital or CAH inpatient or emergency department (POS 21 or 23) during the EHR reporting period.
• Numerator: The number of orders in the denominator recorded using CPOE.
• Threshold: The resulting percentage must be more than 60 percent in order for an EP, eligible hospital, or CAH to meet this measure.
• Exclusion: Any EP who writes fewer than 100 laboratory orders during the EHR reporting period.

Measure 3: More than 60 percent of diagnostic imaging orders created by the EP or authorized providers of the eligible hospital or CAH inpatient or emergency department (POS 21 or 23) during the EHR reporting period are recorded using computerized provider order entry.

• Denominator: Number of diagnostic imaging orders created by the EP or authorized providers in the eligible hospital or CAH inpatient or emergency department (POS 21 or 23) during the EHR reporting period.
• Numerator: The number of orders in the denominator recorded using CPOE.
• Threshold: The resulting percentage must be more than 60 percent in order for an EP, eligible hospital, or CAH to meet this measure.
• Exclusion: Any EP who writes fewer than 100 diagnostic imaging orders during the EHR reporting period.

Medicare and Medicaid Programs; Electronic Health Record Incentive Program—Stage 3 and Modifications to Meaningful Use in 2015 Through 2017; Final Rule

MACRA and Order Entry Requirements

The Medicare Access and CHIP (Children’s Health Insurance Program) Reauthorization Act of 2015 (MACRA) mandated that the Medicare Electronic Health Record (EHR) Incentive Program come to an end on December 31, 2016. One of the new payment mechanisms for Medicare established by MACRA is the Merit-Based Incentive Payment System (MIPS). Under the primary reporting method of MIPS, an eligible provider is not required to report to the Centers for Medicare & Medicaid Services (CMS) that medication, laboratory, and diagnostic imaging orders are being entered by credentialed medical assistants or licensed health care professionals.

CMS, however, offers eligible providers an alternate reporting method under MIPS. Under this method, providers are permitted to report on optional measures, such as computerized provide order entry (CPOE).

This issue will be addressed in greater detail in the upcoming January/February 2017 issue of CMA Today. In the meantime, all past Public Affairs articles by CEO Balasa can be found on the AAMA website.