We have received a number of questions over the past month concerning Meaningful Use and the definitions established by CMS on who is considered a "Licensed Healthcare Professional" for purposes of entering Computerized Physician Order Entry (CPOE) for Meaningful Use.
It is important to note that regardless of what stage of Meaningful Use you consider, both stages require CPOE to be entered by a "licensed healthcare professional".
The definition of who qualifies has become an issue for those practices that utilize Medical Assistants or Scribes to assist their supervising physicians in entering CPOE in the clinical setting. Medical Assistants and Scribes are unusual as they typically are not required to be licensed by the state in which they practice. They perform functions permitted by state law under protocols established by a supervising physician.
In the summer of 2012 CMS published a clarification in the Federal Register that provided an expansion of the definition of a "licensed healthcare professional" to include Certified Medical Assistants. This expanded definition means that only Licensed Professionals or Certified Medical Assistants can enter CPOE for purposes of Meaningful Use.
The key thing to consider when reviewing the potential impact of this definition is the existence of a state license for any staff that you have entering orders into electronic medical record. Orders entered by non-licensed professionals or non-certified Medical Assistants will not be counted towards Meaningful Use compliance.
For those practices that feel they need to pursue certification options for existing or future staff, we are currently preparing a document of those recognized certifying bodies and will distribute an analysis of the various avenues available. We have placed a priority on this analysis and hope to have it ready shortly.
Please feel free to send me any questions you may have on this issue, [email protected].
I have attached a couple source documents to provide additional details on this topic.
1. Federal Register Documentation from 2012.
2. AAMA article.
3. Stage 1 vs Stage 2 Meaningful Use Comparison Table.