CMS Agrees that JCAHPO Certificants (COA, COT, COMT) Can Enter CPOE Orders for Meaningful Use
JCAHPO is aware that there have been some questions recently in some parts of the ophthalmic community regarding which staff members are allowed to enter medication or laboratory orders under the CMS EHR Incentive Program for Computerized Provider Order Entry (CPOE) meaningful use. After considering all of the relevant regulations and CMS guidance, we believe that orders entered by credentialed ophthalmic assistants are included in the meaningful use criterion calculation as long as the applicable requirements are met.
Recent CMS guidance confirms our interpretation of the requirements. Elizabeth Myers, the Policy and Outreach Lead at the CMS Office of eHealth Standards and Services stated on May 13, 2014, that as it relates to entering orders into EHR programs that JCAHPO certifications "count if they are they [sic] equivalent of a CMA. We don't specify every single variation on Medical Assistant because if we made a list and left someone out it would cause a problem. Instead we specify that: 1) The job title doesn't have to be "Medical Assistant" and 2) They don't have to be certified by AAMA. We just use the AAMA definition of what 'certified' means which is certified by an accredited credentialing body outside the organization employing the MA.
JCAHPO is an Accredited Credentialing body. For more than 30 years, JCAHPO's three core certifications have been accredited by the National Commission for Certifying Agencies. Certified Ophthalmic Assistants (COA), Certified Ophthalmic Technicians (COT), and Certified Ophthalmic Medical Technologists (COMT) have received credentials appropriate under the EHR Incentive Program requirements as confirmed by this response from CMS to JCAHPO and other organizations' questions. It is the duty of each individual provider, however, to determine whether his or her staff members are appropriately credentialed under the regulations. Before orders entered by a particular staff member are included in the Incentive Program calculation, a provider should first document that the staff member meets the required criteria.
You can read the CMS Order Entry Statement from the Executive Director and Legal Counsel of the AAMA, Donal A. Balasa, JB, MBA, here.