Under the Meaningful Use Stage 2 Measures both Eligible Professionals and Eligible Hospitals must use Computerized Provider Order Entry (“CPOE”) for medication, laboratory and radiology orders directly entered by any licensed health care professional who can enter orders into the medical record per state, local and professional guidelines. Previously, the Centers for Medicare & Medicaid Services (“CMS”) clarified that a licensed health care professional includes licensed nurses, as well as adding that credentialed medical assistants may also enter CPOE and have the order count towards meeting the applicable meaningful use measure. CMS does require that a credentialed medical assistant receive his or her credentiality from an organization other than the eligible provider.
Most recently, CMS updated its FAQs noting that an individual other than those with the title of medical assistant may be able to enter CPOE. CMS clarifies in FAQ 9058 that if a staff member of the eligible provider is appropriately credentialed and performs similar assistive services as a medical assistant, but carries a more specific title due to either specialization of their duties or to the speciality of the medical professional they assist, he or she can use the CPOE function of Certified Electronic Health Record Technology and have it count towards the measure. CMS provides additional details noting that this determination must be made by the eligible provider based on individual workflow and the duties performed by the staff member in question.
Eligible providers should take note that independent of whether a staff member carries the title of medical assistant or another job title, he or she must still be credentialed to perform the medical assistant services by an organization other than the employing organization. Finally, each eligible provider must evaluate his or her own ordering workflow, including the use of CPOE, to ensure compliance with all applicable federal, state and local law and professional guidelines.
If you have any questions about meaningful use, please contact Ammon Fillmore at 317-977-1492 or afillmore@wp.hallrender.com, Jeff Short at 317-977-1413 or jshort@wp.hallrender.com or your regular Hall Render attorney.
