The laws of most states give physicians (either explicitly or implicitly) the right to delegate patient counseling to competent and knowledgeable medical assistants working under their direct supervision in outpatient settings. When engaging in such counseling, medical assistants must present information reviewed and approved by the overseeing/delegating/supervising physician(s), and must not be required to exercise any independent professional judgment or to make any clinical assessments or evaluations.
The question has arisen as to whether medical assistants, including CMAs (AAMA), are “other qualified healthcare personnel” for the purposes of vaccine coding. Note the following explanation of how Current Procedural Terminology (CPT) defines a “qualified health care provider”:
[T]hose providers whose scope of practice as defined by regulation permits them to perform the service represented by the specific code [with acknowledgment that] licensure and credentialing vary on a state-by-state and institutional basis [and that]relevant state and institutional authorities should be consulted regarding the appropriate reporting of these services by qualified health care professionals.1
The American Academy of Pediatrics (AAP) also provides insight into the matter:
In order to report CPT codes 90460-90461, either the physician or the qualified health care professional who is reporting the service must perform face-to-face counseling (and so document that the counseling was personally performed). To determine if someone other than a physician meets the criteria of a qualified health care professional, each practice should refer to their particular state scope of practice laws. 2
The AAMA takes the position that—because under most state laws physicians are permitted to delegate patient counseling to competent medical assistants working under their direct supervision—CPT codes 90460–90461 can be used when a medical assistant provides counseling that presents information reviewed and approved by the overseeing/delegating/supervising physician(s), and does not require the medical assistant to exercise any independent professional judgment or to make any clinical assessments or evaluations.
Questions? Contact Donald A. Balasa, JD, MBA, at firstname.lastname@example.org or 800/228-2262.