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Stage 3 meaningful use proposal issued; amt comments on CPOE provisions.

Under the proposed Stage 3 Electronic Health Record (EHR) Meaningful Use program, credentialed medical assistants will continue to have authority to enter lab, imaging, and pharmacy orders into the Computerized Provider Order Entry (CPOE) system, and "laypersons" such as scribes and administrative assistants will continue to be precluded from using the CPOE system.

The Stage 3 Electronic Health Record (EHR) Meaningful Use proposed rule was published by CMS in the March 30, 2015 Federal Register. The Stage 3 program will become mandatory in 2018; however, eligible providers would have the option to move to Stage 3 starting in 2017.

The proposed Stage 3 rule outlines new criteria that eligible professionals, eligible hospitals and critical access hospitals must meet to qualify for Medicare and Medicaid EHR incentive payments and avoid Medicare payment adjustments based on program performance beginning in 2018.

Of greatest interest to AMT's membership, the proposed rule maintains the requirement that CPOE entries be executed by either a licensed health provider or a credentialed medical assistant, or the equivalent. Specifically, orders may be 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." The credential must be awarded by an entity other than the medical assistant's employer.

The proposed rule goes on to emphasize that, although employers have discretion to determine what type of credential will assure that their staff has the requisite clinical training to perform the CPOE function, providers may not use "laypersons" for this purpose. The credential must assure clinical training equivalent to that of a medical assistant who has been certified by an independent third party. Thus, CMS continues to recognize the important clinical knowledge possessed by medical assistants, as compared with other medical office staff.

In Stage 2, the CPOE function included orders for medication, laboratory, and radiology services. Under the Stage 3 proposal, the radiology aspect would be expanded to include not only traditional radiology services, but most other types of diagnostic imaging as well, including ultrasound, magnetic resonance, and computed tomography. Among other changes proposed for Stage 3 are significantly increased targets for use of EHR. For example:

* 80% of prescriptions would be required to be sent electronically, up from 60% under Stage 2;

* 60% of lab and imaging orders would be required to be sent electronically, compared with 30% under Stage 2;

* 25% of patients would have to view, download or transmit data from their records, compared with 5% under Stage 2; and

* 25% of patients would have to have engaged in secure messaging with a provider, compared with 5% under Stage 2.

AMT's legal counsel submitted brief comments to CMS prior to the May 29 comment deadline supporting the agency's continued recognition of credentialed medical assistants and its decision not to allow other unlicensed medical office personnel to use the CPOE system. AMT also suggested that CMS more clearly define the type of medical assisting credential or "equivalent" that will qualify an individual to enter orders in CPOE.

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, 2015
Words:531
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