Standing Orders and Supervision Requirements

I welcome further questions about my blog posts because addressing those questions allows me to dive deeper into a pertinent topic for medical assistants who wish to better understand their scope of practice.

For instance, in response to my blog post “Standing Orders from an Overseeing Provider,” I received the following question:

Does a standing order change the supervision requirements for medical assistants? For example, if our state law requires the delegating licensed provider to be on the premises when a medical assistant is performing venipuncture, is this supervision requirement changed by a standing order from the provider?

A standing order does not change the supervision requirement established by state law. The supervision requirements apply regardless of whether the licensed provider issues a standing order, verbal order, or written order. If this were not the case, a provider could circumvent supervision requirements by issuing standing orders instead of verbal orders.

The purpose of supervision requirements is patient protection.

Massachusetts Law Outlines Delegation of Immunizations

In 2016 the Massachusetts legislature passed legislation that permits primary care providers to delegate the administration of immunizations to a medical assistant who is the following:

… is a graduate of a post-secondary medical assisting education program accredited by the Committee on Allied Health Education and Accreditation of the American Medical Association, or its successor, the Accrediting Bureau of Health Education Schools, or its successor or such other certificate program as the commissioner of public health shall approve; (ii) is employed in the medical practice of a licensed primary care provider; and (iii) who performs basic administrative, clerical, and clinical duties upon the specific authorization and under the direct supervision of a licensed primary care provider.

Note the following definitions from the legislation:

Direct supervision: “Oversight of a certified medical assistant exercised by a primary care provider who is present in the facility and immediately available to furnish assistance and direction throughout the course of the performance of a delegated procedure but is not required to be present in the room when the procedure is being performed.”

Primary care provider: “A health care professional qualified to provide general medical care for common health care problems who: (i) supervises, coordinates, prescribes, or otherwise provides or proposes health care services; (ii) initiates referrals for specialist care; and (iii) maintains continuity of care within the scope of practice.”

The legislation directs the Massachusetts Department of Public Health to promulgate regulations regarding the specifics of the delegation of immunizations. The full text of the legislation can be found on the AAMA website, under State Scope of Practice Laws.