The following comments concerning Sections 4723.48(C) and 4723.489 of the Ohio Revised Code were submitted to the Ohio Board of Nursing in January 2016.

The Ohio State Society of Medical Assistants (OSSMA) and the American Association of Medical Assistants (AAMA) appreciate the opportunity to submit comments to the Committee on Practice of the Ohio Board of Nursing about language for proposed rules implementing Sections 4723.48(C) and 4723.489 of the Ohio Revised Code.1,2 These comments will address 4723.489(D):

The person has successfully completed education based on a recognized body of knowledge concerning drug administration and demonstrates to the person’s employer the knowledge, skills, and ability to administer the drug safely.2

It is the position of the OSSMA and the AAMA that individuals who have graduated from a postsecondary medical assisting academic program accredited by either the Commission on Accreditation of Allied Health Education Programs (CAAHEP) or the Accrediting Bureau of Health Education Schools (ABHES) have “successfully completed education based on a recognized body of knowledge concerning drug administration.”2 The current CAAHEP Standards for the Accreditation of Educational Programs in Medical Assisting3 and the ABHES Accreditation Manual4 are attached. Note Appendix B of the CAAHEP Standards and Chapter VII of the ABHES Accreditation Manual.

The Commission on Accreditation of Allied Health Education Programs and the Accrediting Bureau of Health Education Schools are the only programmatic medical assisting accrediting bodies recognized by either the United States Department of Education (USDE) or the Council for Higher Education Accreditation (CHEA). The medical assisting standards of both CAAHEP and ABHES require that students master both the didactic knowledge as well as the psychomotor competencies necessary for safe medication administration.

It is also the position of the [OSSMA] and the [AAMA] that, in addition to language requiring the completion of “education based on a recognized body of knowledge concerning drug administration,”2 the rules of the Ohio Board of Nursing implementing 4723.489(D) should also contain language requiring the person to have passed an examination and be granted a credential that verifies the person’s knowledge concerning drug administration, such as the CMA (AAMA) Certification Examination and the CMA (AAMA) credential. Requiring completion of appropriate education, but not requiring the passing of an accredited credentialing examination and the maintaining of the currency of such a credential by periodic recertification, does not adequately protect patients, the delegating advanced practice registered nurses, and the delegatees.

In summation, the OSSMA and the AAMA urge the Committee on Practice of the Ohio Board of Nursing to incorporate into the regulation implementing Sections 4723.48(C) and 4723.489 the following three points: (1) that graduates of medical assisting programs accredited by either CAAHEP or ABHES have met the requirement of 4723.489(D) that the person “has successfully completed education based on a recognized body of knowledge concerning drug administration;” (2) that the person be required to have passed an examination and be granted a credential that verifies the person’s knowledge concerning drug administration, and to keep the credential current by periodic continuing education or retesting; and (3) that medical assistants who have a current, accredited medical assisting credential, such as the CMA (AAMA), have met the credentialing requirement.

Thank you again for the opportunity to submit comments to the Committee on Practice of the Ohio Board of Nursing.

Questions? Contact Donald A. Balasa, JD, MBA, at dbalasa@aama-ntl.org, or call the AAMA at 800/228-2262.