The following comments concerning the proposed New Rule I “Medical Assistant—Delegation and Supervision”1 were submitted to the Montana Board of Medical Examiners on May 29, 2018. Following the comments is an excerpt from the proposed new rules.

The Montana Society of Medical Assistants (MSMA) and the American Association of Medical Assistants (AAMA) submit the following comments on the proposed New Rule I “Medical Assistant—Delegation and Supervision” of the Montana Board of Medical Examiners, Montana Department of Labor and Industry.

The MSMA and AAMA agree with the Montana Board of Medical Examiners that the current medical assistant rule is “confusing and arcane and no longer reflects current practice in the medical field.” We thus commend the Board of Medical Examiners for submitting a total rewrite of the rule and for the clarity and straightforwardness of the proposed new rule.

The primary public policy objective of the [MSMA and AAMA] is to protect patients from substandard medical assisting services. In light of this objective, the MSMA and AAMA express concern with the following section of the proposed rule:

(c) personally provide onsite direct supervision as defined by ARM [Administrative Rules of Montana] 24.156.501 to a medical assistant to whom the health care provider has delegated:

(i) injections other than immunizations;
(ii) invasive procedures;
(iii) conscious sedation monitoring;
(iv) allergy testing;
(v) intravenous administration of blood products; or
(vi) intravenous administration of medication; and

It is the position of the Montana Society of Medical Assistants and the American Association of Medical Assistants that the above tasks should be delegable only to medical assistants: (1) who have graduated from a postsecondary, programmatically accredited medical assisting program and (2) who have a current medical assisting credential, such as the CMA (AAMA), accredited by a national accrediting body such as the National Commission for Certifying Agencies (NCCA). Only those medical assistants who have demonstrated mastery of the required knowledge and psychomotor skills by completing an accredited medical assisting program, passing a standardized medical assisting examination, and maintaining the credential by periodic recertification should be delegated the tasks set forth in (c)(i through vi).

Questions from readers may be directed to CEO Donald A. Balasa, JD, MBA, at dbalasa@aama-ntl.org, or by calling the AAMA at 800/228-2262.