The following are comments submitted by the Alaska Medical Assistant Society to the Alaska Board of Nursing (BON) prior to a July 9, 2008 hearing in Anchorage, Alaska. The purpose of the hearing was to receive opinions as to whether the rules of the Alaska BON should be amended to permit Advanced Nurse Practitioners (ANPs) to delegate the administration of injectable medications to medical assistants.

Robin Wahto, RN, CMA (AAMA), representing the Alaska Medical Assistant Society, presented oral testimony at the hearing that explained and amplified the comments below. As executive director and legal counsel of the American Association of Medical Assistants, I presented oral testimony via telephone.

There is no set timeline for resolution of this issue in Alaska. The decision making process of the Alaska Board of Nursing may extend over several months.

 

The Alaska Medical Assistant Society is grateful for this opportunity to submit comments to the Alaska Board of Nursing in regard to 12 AAC 44.970(a)(13), which reads as follows:

 

Nursing duties that require the exercise of professional nursing knowledge or judgment or complex nursing skills may not be delegated. Nursing duties that may not be delegated include

……

(13) administration of injectable medications

 

The primary public policy objectives of the Alaska Medical Assistant Society (AMAS) (and the American Association of Medical Assistants) are: (1) to increase the quality and availability of health care for all; and (2) to protect patients and employers from substandard medical assisting services by advocating for regulations and legislation that require medical assistants who are being delegated certain advanced procedures (e.g., administration of injectable medications) to be:

 

(A) graduates of a medical assisting program accredited by the Commission on Accreditation of Allied Health Education Programs (CAAHEP) or by the Accrediting Bureau of Health Education Schools (ABHES); and (B) current Certified Medical Assistants (CMAs) of the American Association of Medical Assistants (AAMA) or current Registered Medical Assistants (RMAs) of the American Medical Technologists (AMT), which are the only credentialing examinations accredited by the National Commission for Certifying Agencies (NCCA).

 

Specifically, it is the position of the Alaska Medical Assistant Society that the regulations of the Alaska Board of Nursing should be amended to permit Advanced Nurse Practitioners (ANPs) to delegate the administration of injectable medications to medical assistants who: are graduates of a medical assisting program accredited by either CAAHEP or ABHES (the only programmatic accrediting bodies for postsecondary medical assisting programs); and hold a current medical assisting credential accredited by the NCCA. Such delegation should be under the Advanced Nurse Practitioner’s direct supervision, and should meet all the delegation requirements specified in the pertinent statutes and rules.

 

With the 26 Community Health Centers and their 145 clinic sites in Alaska, it is imperative that the availability of health care be maximized by permitting Advanced Nurse Practitioners to delegate injections to competent and knowledgeable medical assistants working under the direct supervision of ANPs. However, it is also imperative that the quality of health care not be diminished. Allowing ANPs to delegate the administration of injectable medications only to formally educated and credentialed medical assistants would result in both of these public policy objectives being met. The Commission on Accreditation of Allied Health Education Programs (CAAHEP) Standards and Guidelines for the Accreditation of Educational Programs in Medical Assisting are attached. The medical assisting accreditation standards of the Accrediting Bureau of Health Education Schools (ABHES) are substantially equivalent. Also attached is the Content Outline of the CMA (AAMA) Certification Examination. The CMA (AAMA) exam, as well as the RMA exam given by the American Medical Technologists, are the only medical assisting certifications accredited by the National Commission for Certifying Agencies (NCCA).

 

The Alaska Medical Assistant Society recommends that the Alaska Board of Nursing consider promulgating regulations similar to those of the North Dakota Board of Nursing (BON) (attached). Medical assistants permitted to be delegated injections are classified as “medication assistants III” in the rules of the North Dakota BON. 54-07-05-01 of the North Dakota Century Code (NDCC) states that “The medication assistant III may perform the intervention of administering medications to the client in an ambulatory health care setting.” 54-07-05-04(2) states: “In an ambulatory health care setting where the licensed nurse delegates the intervention of giving medications to another individual, the licensed nurse must be available for direction.”

 

The requirements for becoming a medication assistant III in North Dakota law are delineated in 54-07-05-05(4):

 

Unlicensed assistive persons may obtain initial medication assistant III registration by:

a. Submitting evidence of successful completion of two semesters of an approved nursing education program, each of which must have included a clinical nursing component. The two semesters combined must have included basic clinical skills, basic pharmacology, principles of medication administration, and mathematics competency; or

b. Submitting evidence of:

(1) Successful completion of a board-recognized medical assistant program; and

(2) Certification from the American Association of Medical Assistants or its successor organization awarding the Certified Medical Assistant credential or registration from the American Medical Technologists or its successor organization awarding the Registered Medical Assistant credential.

 

Routes of types of medication administration are set forth in 54-07-05-09(3):

 

3. Medication assistants III may administer medications by the following routes to individuals or groups of individuals with stable, predictable conditions according to organization policy:

a. Intramusclar injections

b. Subcutaneous injections

c. Intradermal injections

d. Gastrostomy

e. Jejunostomy

 

Note the following in 54-07-05-09(6):

 

6. Medication assistants III may not administer medications by the following routes:

a. Central lines

b. Colostomy

c. Intravenous

d. Intravenous lock

e. Nasogastric tube

f. Nonmetered inhaler

g. Nonunit dose aerosol/nebulizer

h. Urethral catheter

 

Thank you for this opportunity for the Alaska Medical Assistant Society to submit comments on the delegation of administration of injectable medications. Please let us know whether we can provide further information or answer any questions.

Any questions about this issue may be directed to Executive Director Donald A. Balasa, JD, MBA, at dbalasa@aama-ntl.org.