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AMT comments on Stage 2 EHR "meaningful use" Regs.

On May 7, 2012, AMT submitted targeted comments on one aspect of CMS's proposed Stage 2 Electronic Health Records (EHR) "meaningful use" regulations. The proposed rule, published March 7, would specify the Stage 2 criteria that eligible professionals, eligible hospitals, and critical access hospitals must meet in order to qualify for Medicare and Medicaid EHR incentive payments. In addition, it would specify payment penalties for such providers who fail to demonstrate meaningful use of certified EHR technology and other program participation requirements.

AMT's comments focused on CMS's proposed objective relating to the Computerized Provider Order Entry (CPOE) system. The proposed objective is described by CMS as follows:
 Use computerized provider order entry (CPOE) for medication,
 laboratory and radiology orders directly entered by any licensed
 healthcare professional who can enter orders into the medical
 record per State, local and professional guidelines to create
 the first record of the order. [77 Fed. Reg. 13708.]

The proposed objective would expand the definition of CPOE to include a provider's use of computer assistance to order laboratory and radiology services, as well as medications (only medications were included in the Stage 1 definition). AMT supported CMS's recommendation to include laboratory and radiology orders, agreeing that the expansion to laboratory and radiology orders furthers the goals of the CPOE objective and is a logical step in the progression of meaningful use.

CMS also invited comment on "whether the [Stage 1] stipulation that the CPOE function be used only by licensed healthcare professionals remains necessary or if CPOE can be expanded to include nonlicensed healthcare professionals such as scribes."

AMT responded that it strongly believes the CPOE function should be expanded to allow properly credentialed, unlicensed healthcare professionals to perform the data entry aspect of CPOE. AMT's comments summarized the education, training and examination requirements to become certified as a Registered Medical Assistant (RMA), and noted that medical assistants are trained to perform a wide variety of both front-office (administrative) and back-office (clinical) tasks in a medical practice setting.

AMT's comments observed, "These duties typically include the completion of requisitions for laboratory and radiology services, as well as the transcription of prescription orders for patients of the medical practice or clinic, pursuant to an order by the attending physician." As a result, "AMT believes that properly credentialed medical assistants are well qualified to perform the physical data entry function CPOE under the direct supervision of a licensed healthcare practitioner." AMT suggested that to be considered properly credentialed, a medical assistant should hold a current certification by an organization accredited by the NCCA or ANSI.

As of this writing, CMS was still sifting through thousands of comments received on its Stage 2 proposal, of which the CPOE objective was just one piece.

by AMT Legal Counsel Michael N. McCarty Brickfield, Burchette, Ritts & Stone, P.C.
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Title Annotation:government news
Author:McCarty, Michael N.
Publication:AMT Events
Date:Jun 1, 2012
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