The role of medical assistants—especially CMAs (AAMA)—in the Medicare Annual Wellness Visit (AWV) continues to be a topic of interest and inquiry for health care professionals. The latest Public Affairs article attempts to clarify what AWV tasks are and are not delegable to medical assistants. Read “The Role of Medical Assistants in the Medicare Annual Wellness Visit” in the July/August 2018 issue of CMA Today on the AAMA website.
There seems to be some confusion about what a medical assistant is permitted to do in connection with a Medicare Annual Wellness Visit (AWV). Let’s start with a description of a Medicare AWV from the May/June 2015 CMA Today article “Prioritizing Prevention: Medicare’s Annual Wellness Visit”:
The yearly wellness visit provides seniors with a general health-risk assessment that includes screenings for depression, cognitive impairment, and other health concerns. At the visit, health care providers review the patient’s medical and family history, document vital measurements, such as height, weight, and blood pressure, and update lists of current providers and prescriptions. At the conclusion of the visit, the patient is provided with a personal health plan, including a long-term schedule for future screenings and preventive services.
Note the following document from the Centers for Medicare & Medicaid Services (CMS), “The ABCs of the Annual Wellness Visit”:
Medicare Part B covers an AWV if performed by a:
- Physician (a doctor of medicine or osteopathy)
- Qualified non-physician practitioner (a physician assistant, nurse practitioner, or certified clinical nurse specialist)
- Medical professional (including a health educator, registered dietitian, nutrition professional, or other licensed practitioner) or a team of medical professionals who are directly supervised by a physician (doctor of medicine or osteopathy)
It is my legal opinion that federal law permits medical assistants to assist licensed health care providers (e.g., MDs/DOs, nurse practitioners, physician assistants) in the performing of an AWV. However, medical assistants are not permitted to perform any part of the AWV that requires the medical assistant to make independent clinical judgments or to make clinical assessments or evaluations.
Although I have written about the difference between medical assistants and medication aides/assistants/technicians in Public Affairs articles in CMA Today, I continue to receive questions about the topic. Here are the basics:
Medical assistants work in outpatient settings under direct provider supervision, and may be delegated clinical and administrative tasks. Medication aides/assistants/technicians work in inpatient settings, usually under registered nurse supervision. A primary task of medication aides is to pass medications as directed by the RN supervisor.
Medication aides do not exist under the laws of some states. The laws of other states refer to these health workers by a designation other than medication aide. In some states an individual must first meet the requirements and register with the state as a certified nursing assistant (CNA) in order to be eligible to receive additional training and become a medication aide.
Medical assistants do not work in a clinical capacity in inpatient settings as medical assistants per se. Medical assistants must meet the requirements and register with the state as a CNA and/or a medication aide in order to work in a clinical capacity in inpatient settings.
Some state laws refer to medication aides as “certified medication aides.” The initialism associated with this phrase can cause confusion between medical assistants and medication aides. To help minimize such confusion, the National Council of State Boards of Nursing refers to medication aides as “MA-Cs” and encourages states to use this initialism. This change was made at the request of the American Association of Medical Assistants.
As many readers of this blog know, I write at length about legal issues affecting the medical assisting profession in each issue of CMA Today, the official publication of the American Association of Medical Assistants. Recently, one of those articles was referenced in a question-and-answer piece in Part B News. (Note: Subscription required.)
The write-up discusses CPT code 69209 (Removal of cerumen using irrigation/lavage) and whether the procedure can be billed if a medical assistant performs it. The author notes several important considerations—for example, the differences in state law and the vagaries of some CPT language—in addition to discussing the CPT definition of “clinical staff” as it relates to medical assistants. Ultimately, the author states the following:
In aggregate, when it comes to medical assistants being eligible to perform services incident to a physician, the answer is “generally yes,” according to recent guidance from the American Association of Medical Assistants (AAMA).
The language the author cited was from my article “‘Incident-to’ billing: Medical assistants’ services under the Medicare CCM program,” which can be found on the AAMA website.
This blog frequently discusses scope-of-practice issues, but health care always provides new questions to examine. This post will address the following: Are medical assistants permitted to work in a dental office under the authority/supervision of a dentist?
First of all, it is important to keep in mind the distinction between a dental hygienist and a dental assistant. Under the laws of all American jurisdictions, dental hygienists are required to be licensed. Licensure for dental hygienists requires graduation from a postsecondary dental hygiene academic program and the passing of a national (and in some cases, state) examination. Thus, medical assistants—including CMAs (AAMA)—are not permitted to work as dental hygienists.
Under the laws of some states, dental assistants are required to have formal education and pass a test in order to be delegated certain tasks by the overseeing/delegating dentist. Other states have no educational or testing requirements for dental assistants. A medical assistant should check with the state board of dental examiners (usually in the state capital) to find out whether the state has any educational or testing requirements for dental assistants, and whether any of the medical assisting education or credentialing can be used toward meeting any state requirements for dental assistants.