CMS continues to reinforce the need for appropriate credentialing related to computerized order entry and EHR meaningful use. In March 2018, CMS sent a reminder to providers to review compliance information for EHR meaningful participation, providing a list of Frequently Asked Questions (FAQ) for reference. The second question in this list, FAQ #2851, states:
Question: Who can enter medication orders in order to meet the measure for the computerized provider order entry (CPOE) meaningful use objective under the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs?
Answer: As mentioned in 80 FR 62798, a medical staff person who is a credentialed medical assistant or is credentialed to and performs the duties equivalent to a credentialed medical assistant may enter orders. We maintain our position that medical staff must have at least a certain level of medical training in order to execute the related CDS for a CPOE order entry. We defer to the provider to determine the proper credentialing, training, and duties of the medical staff entering the orders as long as they fit within the guidelines we have proscribed. We believe that interns who have completed their medical training and are working toward appropriate licensure would fit within this definition. We maintain our position that, in general, scribes are not included as medical staff that may enter orders for purposes of the CPOE objective. However, we note that this policy is not specific to a job title but to the appropriate medical training, knowledge, and experience.
To read more, you can view this FAQ document OR visit the CMS Frequently Asked Questions Page and select “Objectives and Measures.”