Centers for Medicare & Medicaid Services, Computerized Provider Order Entry (CPOE), EHR Incentive Programs, Medicaid, Uncategorized

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

Centers for Medicare & Medicaid Services, Computerized Provider Order Entry (CPOE), EHR Incentive Programs, On the Job

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

Computerized Provider Order Entry (CPOE), EHR Incentive Programs, Eligible Professionals, Medicaid, On the Job

Order Entry Requirements for Non-Physician Practitioners

I was recently asked whether non-physician practitioners (e.g., nurse practitioners and physician assistants) must meet the meaningful use order entry requirements under the Medicaid Electronic Health Record (EHR) Incentive Program.  The answer is yes.

The following are considered “eligible professionals” (EPs) who can participate in the  Medicaid EHR Incentive Program:

  • Physicians (primarily doctors of medicine and doctors of osteopathy)
  • Nurse practitioners
  • Certified nurse-midwives
  • Dentists
  • Physician assistants who furnish services in a Federally Qualified Health Center or Rural Health Clinic that is led by a physician assistant

All participating EPs must meet the computerized provider order entry (CPOE) requirements of the Incentive Program in order to receive incentive payments.

Certification and the CMA (AAMA) Credential, Computerized Provider Order Entry (CPOE), EHR Incentive Programs, Meaningful Use, Medicaid, Medicare, On the Job, Scope of Practice

Addressing Recent Concerns About Order Entry

The Centers for Medicare and Medicaid Services (CMS) Blog recently posted these articles dealing with forthcoming changes to the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs:

EHR Incentive Programs: Where We Go Next

Comments of CMS Acting Administrator Andy Slavitt at the J.P. Morgan Annual Health Care Conference, Jan. 11, 2016

In the wake of these pieces, there has been some concern about the potential effects on medical assistants’ ability to enter orders into the computerized provider order entry (CPOE) system for meaningful use purposes. I have addressed these concerns in a memorandum to AAMA leaders. The body of this message is as follows:

January 22, 2016

Within the last 10 days the Centers for Medicare and Medicaid Services (CMS) has issued statements about forthcoming changes in the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs (Incentive Programs) required by the passage of the Medicare Access and Children’s Health Insurance Program (CHIP) Reauthorization Act of 2015, referred to as “MACRA.”

Congress enacted MACRA on April 16, 2015.  This legislation replaces the current meaningful use (MU) payment adjustment provisions with the Merit-Based Incentive Payment System (MIPS), effective January 1, 2019.  According to CMS, MIPS will incorporate some meaningful use elements of the current program and will introduce new elements.

There has been a groundswell of concern that MACRA will do away with the requirement that only third-party-credentialed medical assistants, licensed health care professionals, and third-party-credentialed individuals “who hold a more specific title than ‘medical assistant’ because their duties include only parts of the medical assisting scope of practice, or because of the specialization of the overseeing eligible professional (EP),” are permitted to enter medication, laboratory, and diagnostic imaging orders into the computerized provider order entry (CPOE) system for meaningful use calculation purposes under the Incentive Programs.

In my legal opinion, this concern is not warranted because of the following:

  1. The order entry credentialing requirement of the Incentive Programs was established by CMS rule, not by federal statute.
  2. No provisions of MACRA impact the CMS order entry credentialing requirement.
  3. The legislative history of MACRA does not indicate that Congress was concerned about the CMS order entry credentialing requirement.

CMS regulations implementing MACRA and MIPS are scheduled to be published for comment in 2016.  I do not anticipate that these forthcoming regulations will include any changes to the credentialing requirement of the CMS MU order entry rule.  However, if changes are proposed that could potentially harm patients by lowering the credentialing requirement for medical assistants who enter orders into a CPOE system, the American Association of Medical Assistants will be quick to point this out to CMS decision makers, and to persuade them to maintain or increase the current requirement.

Certification and the CMA (AAMA) Credential, Computerized Provider Order Entry (CPOE), EHR Incentive Programs, Meaningful Use, Medicaid, Medicare, On the Job, Scope of Practice

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