Quoting from HIPAA Regulation: §164.312

A covered entity must, in accordance with §164.306:

(a) (1) Standard: Facility access controls. Implement policies and procedures to limit physical access to its electronic information systems and the facility or facilities in which they are housed, while ensuring that properly authorized access is allowed.

(2) Implementation specifications:

(i) Contingency operations (Addressable). Establish (and implement as needed) procedures that allow facility access in support of restoration of lost data under the disaster recovery plan and emergency mode operations plan in the event of an emergency.

(ii) Facility security plan (Addressable). Implement policies and procedures to safeguard the facility and the equipment therein from unauthorized physical access, tampering, and theft.

(iii) Access control and validation procedures (Addressable). Implement procedures to control and validate a person's access to facilities based on their role or function, including visitor control, and control of access to software programs for testing and revision.

(iv) Maintenance records (Addressable). Implement policies and procedures to document repairs and modifications to the physical components of a facility which are related to security (for example, hardware, walls, doors, and locks).

(b) Standard: Workstation use. Implement policies and procedures that specify the proper functions to be performed, the manner in which those functions are to be performed, and the physical attributes of the surroundings of a specific workstation or class of workstation that can access electronic protected health information.

(c) Standard: Workstation security. Implement physical safeguards for all workstations that access electronic protected health information, to restrict access to authorized users.

(d) (1) Standard: Device and media controls. Implement policies and procedures that govern the receipt and removal of hardware and electronic media that contain electronic protected health information into and out of a facility, and the movement of these items within the facility.

(2) Implementation specifications:

(i) Disposal (Required). Implement policies and procedures to address the final disposition of electronic protected health information, and/or the hardware or electronic media on which it is stored.

(ii) Media re-use (Required). Implement procedures for removal of electronic protected health information from electronic media before the media are made available for re-use.

(iii) Accountability (Addressable). Maintain a record of the movements of hardware and electronic media and any person responsible therefore.

(iv) Data backup and storage (Addressable). Create a retrievable, exact copy of electronic protected health information, when needed, before movement of equipment.

As you can see, much of this information seems geared more toward larger facilities than on home-based or small office-based transcription service providers; clearly we have to find ways to adapt these regulations to the specifics of each operation. But in general, the physical safeguards section of the HIPAA Security Rule deals with the physical aspects of maintaining security when dealing with electronic protected health information (ePHI). We're talking about things like how you go about providing access to the computer(s) where ePHI will be maintained for any length of time. Is it in a room with a lock on the door? Who has a key? Is the computer in a cabinet or desk that can be locked in some fashion? As I read the regulations, it is necessary to not only have the means to control access to equipment containing ePHI, but you must document that plan and have a way to track every person who accesses equipment where ePHI is stored. This would include the individual(s) performing transcription, of course, but it would also include anyone else who has access to that computer, including anyone performing repairs or maintenance on the equipment. That in itself should be all the incentive you need to make sure you have a dedicated computer that cannot be accessed by anyone not covered under your business associate (BA) agreement with the covered entity (CE). Obviously the fewer people who have access to your equipment, the less onerous your recordkeeping procedures will be.

Notice also that this section of the HIPAA regulations deals with such issues as having a disaster recovery and emergency operations mode plan. What are your provisions for backup and restoration of ePHI in case of power outage, equipment failure, etc.? Furthermore, this rule requires you to have and document a policy regarding removable media which may be used to store ePHI, including USB flash drives, CD-ROMs, DVD-ROMs, portable hard drives, etc. What precautions do you take in regards to any removable media containing ePHI that leaves the workstation? Do you have a log of the who, what and when of such events? Finally, this rule requires that a policy be in place that deals with the destruction/deletion of ePHI when you no longer have reason to maintain it in your possession. How do you go about removing ePHI from your hard drive and/or removable media? How long do you keep ePHI, and do you have a specific procedure in place to make sure files with ePHI are deleted in a timely manner according to your policy?

It's important to note that the HIPAA regulations, in many instances, do not specifically dictate HOW you must physically safeguard ePHI, so there is a certain amount of flexibility inherent in the rule. However, it seems clear to me that the intent of all these regulations is to ensure that, A) the policies and procedures that are put into place do in fact adequately protect ePHI; B) those policies and procedures are in writing; C) all personnel handling ePHI are familiar with these policies and procedures (with documentation to prove it, of course); and D) there is documentation to demonstrate that the policies and procedures are in fact consistently carried out in the BA's day-to-day operations. In my opinion, these four steps are the key to successfully complying with all the provisions of the HIPAA Security Rule regarding ePHI.

In my next post, I'll talk about the HIPAA Security Rule regulation dealing with technical safeguards for ePHI, which is probably the area of greatest concern for MT service owners and independent contractors, who use the Internet to send and receive files containing electronic protected health information.

For this second installment in a series of articles on the added responsibilities for transcription service providers under HITECH, I'll be drawing heavily from information from the HIPAA Survival Guide, specifically the section regarding the HIPAA Security Rule, which deals with electronic protected health information (ePHI). In a nutshell, the Security Rule requires three kinds of safeguards with regard to ePHI: administrative, physical, and technical. It probably won't come as any shock to you, since this is a document created by government bureaucrats, that there's some overlap between these three areas, not to mention the occasional lack of clarity and specificity.

With that in mind, let's look first at the administrative requirements for protecting PHI under HIPAA and HITECH. Keep in mind that although reference is made to covered entities (CEs), with the passage of HITECH, business associates (BAs), including transcription service providers, must also now adhere to the provisions of the Security Rule. According to the HIPAA Survival Guide, administrative safeguards are defined as "administrative actions, policies and procedures, to manage the selection, development, implementation, and maintenance of security measures to protect ePHI and to manage the conduct of the CE's workforce in relation to the protection of that information." My translation of this definition is that one of the requirements for HIPAA compliance is to have written policies that lay out in detail, A) the measures you've put in place to protect ePHI; B) the measures you have in place to deal with any breaches of your written policies on security; and C) the measures you have in place to train your workforce to comply with A and B. But simply having written policies and procedures in place isn't enough; you must also actually enforce them, and be able to document that you have in fact enforced them.

(Did I mention that all of this was dreamed up by bureaucrats?)

Even though I'm mentioning administrative safeguards first, the reality is that order to formulate the written policies and procedures that will guide your operations with regard to security, you first have to have an understanding of what HIPAA and HITECH require in terms of protecting ePHI, which I will deal with in future posts. Once you know what's required in terms of physical and technical safeguards, you'll then be ready to do an assessment of your particular situation to determine what specific threats to security exist in your operational workflow in light of the HIPAA/HITECH requirements. At that point you should be in a position to create the written policies and procedures covering your specific operation.

In this first installment in a series of articles about how the HITECH portion of the ARRA legislation (also known as the stimulus bill) will change the way medical transcriptionists operate, I want to focus on some of the new obligations for business associates, including transcription service providers under the new legislation. A good starting point is this article from For The Record magazine entitled, "Pulling It All Together - The HITECH Act & HIPAA," which deals with some of these new responsibilities for business associates handling electronic protected health information (ePHI). Here are some key passages, with my emphases added:

Breach notification requirements also extend to business associates (BAs). Under HITECH, BAs are now directly accountable for violations. Further, if a BA becomes aware of a violation on the part of a covered entity (CE) with whom it works, it has an obligation to report the breach if the CE does not take steps to remedy the situation.

As a result, BAs that have not already done so will need to implement security and notification policies and procedures of their own, as well as work with CEs to reach agreements on how notifications will be handled.

In most cases, this will require BAs to carefully evaluate and revise existing contracts not only with CEs but also with any subcontractors that may handle personal health information (PHI) on behalf of clients.

“Agreements will have to be amended to reflect that the nature of the relationship between the business associate and covered entity has changed, such that the BA actually has affirmative duties to take certain steps,” says Helen Oscislawski, JD, a health law attorney with Fox Rothschild LLP. “For one, BAs now have a direct obligation, if they are aware a covered entity has engaged in a breach, to report the breach to HHS if the CE fails to take steps to remedy the breach and terminating the contract is not an option. This was in reverse before. Now we have a bilateral, mirrored obligation on both ends. It changes the dynamic between these parties in many ways.”

Further, while previously the determination of whether a BA would be held accountable for breaches was handled in contracts, they are now directly at risk for the same statutory and civil monetary penalties as covered entities, including those pursued by state attorneys general.

As you can see, HITECH has clearly changed the ground rules with regard to who is responsible for securing ePHI. It used to be that the burden was by and large all on the covered entity, i.e., the client, to be HIPAA compliant. That is no longer the case. Under HITECH, business associates must now be proactive in ensuring that all ePHI is handled in a secure manner, whether or not the client sees the need to do so. In my own personal experience as an MT service owner dealing with small physician practices, as well as providing consulting services to other small MTSOs and independent contractors, I'm well aware of the challenge this presents to many of us. Every doctor we deal with, as well as their office personnel, must now be educated on the need for security measures that up to this point may have been ignored.

Furthermore, HITECH not only requires that proper security measures be put in place (more specifics on that in later articles), there must be a written contract between CEs and BAs which clearly spells out the legal obligations of all parties under HIPAA and HITECH. In other words, the days of doing business with a client on the basis of a conversation in person or over the phone are over. Everything has to be in writing, and it has to be very explicit in terms of what each party is required to do under the law. Again, this means that if you don't already have a written HIPAA compliance contract in place for every client, now is the time to get it done. And even if you DO have existing written agreements in place, they must all now be updated to reflect the new obligations under HITECH.

The bottom line is that transcription service providers can no longer afford to sit back and wait for the client to initiate a conversation about contracts and security procedures. Now under HITECH, if we aren't HIPAA compliant, we can be slapped with the same monetary penalties that used to be reserved for covered entities. 

From a post on MTChat.com:

I think MTs are going to start losing actual real jobs a whole heap sooner in greater numbers than most of us are willing to admit is already happening.

It is happening here in our area now and we do have a pretty good working knowledge of what the employment outlook for MTs is here given the client base we have. Getting hired here now is 10 times harder than it has ever been. No one is hiring new staff. No one is adding employees ... no one is picking up ICs ... they are shifting the bulk and burden of what work is left to existing staff only and making do with what they have ... and of course, letting folks go as the accounts continue to automate and walk out the door, usually with no warning. Its has been going on steadily for the last couple of years, it is just that no one really openly talked about it until lately.

I think MTs, especially long-term stay at home independents like you or I, are going to have to start accepting that we have hit the place where there are no choices but to start lowering expectations of what we think the real worth of MT is in the process of medical documentation to stay employed or to doing work that essentially is what I consider as data entry for lower pay. Either that or transition/train for some other field of work as quickly as they can. Two really ugly choices, but that is what is happening here in my area and I doubt that is really any different in other areas of the country. New ones just starting out are not going to know any different because they are gonna be lucky to get hired at all, and, if hired it will be at the ever-dropping rates that are now the norm not the exception.

I've been an optimist when it comes to the future of MT even after many of my colleagues were expressing ever more pessimistic views about the state of the industry. However, lately I've had cause to revisit my opinions on this issue, although for different reasons than those voiced by Renee Priest above. My growing conviction is that it will be enforcement of HIPAA, given dramatically more muscle by the recently passed HITECH legislation, that may very well spell the end for small MTSOs and independent contractors. In following posts I'll be examining in greater detail the specifics of the new requirements for business associates under HIPAA/HITECH, but suffice it to say for now that life as we know it for mom-and-pop operations is about to get a whole lot more complicated.

From the blog of attorney Adam Russo comes a review of an article from Report On Patient Privacy newsletter regarding the recent HIPAA Compliance Review Analysis report issued by the Centers for Medicare & Medicaid Services (CMS):

The first batch of government reviews of covered entities (CEs) for compliance with the security rule revealed a host of deficiencies, ranging from failure to conduct even an initial risk assessment to inconsistent employee training, according to a summary of findings and recommended corrective actions recently released by CMS.

But what is perhaps most interesting is CMS’s apparent belief, expressed in the report, that encryption is mandatory and its statement that risk assessments should be repeated every three years, at a minimum.

CMS said it chose the 10 CEs to review based on “complaints filed against the entities, identification of potential security rule violations through the media, or recommendations from OCR.”

During the reviews, CMS (or its contractors) conducted interviews with individuals at the CEs “to understand the nature of the incident, discuss corrective actions taken since the incident occurred, and identify existing or new processes which protected the confidentiality, availability, and integrity of electronic protected health information (ePHI),” the agency says.

“In addition, CMS examined documented policies and procedures which supported the security of ePHI. For selected key processes, CMS conducted analysis to assess whether the processes were operating effectively and as intended. To maintain visibility of the process, CMS provided regular status reports to the CE throughout the review, and discussed potential gaps in compliance with their representatives.”

CMS concluded that these CEs were “struggling” most with risk assessments; keeping their policies and procedures current; training employees on security compliance; conducting clearance checks on employees; ensuring adequate workstation security; and ensuring encryption is properly employed.

“The two themes that stand out to me in the CMS summary are the importance of well-developed policies and procedures and the obligation of ongoing compliance,” says Chris Bennington, an attorney in the Cincinnati-Dayton office of Bricker & Eckler LLP, whose practice includes health care data privacy issues. “Not surprisingly, many of the compliance issues highlighted by CMS focused on the covered entities’ policies and procedures.”

“A covered entity must not simply develop its security rule policies and procedures, put them in an employee handbook, and then never think about them again,” he adds.

Another problem area, as noted, is “workforce clearance procedures.” The rule requires “appropriate access,” which CMS takes to mean “background investigations on personnel,” for both those with on-site and remote access.

Background investigations on personnel should be conducted before they are given access to electronic PHI, the report states. The audits found CEs sometimes completed such checks after the employee had already been granted such access.

John Parmigiani, president of John Parmigiani & Associates, LLC, an information security consulting firm in Maryland, points out that, as a result of this year’s HITECH Act, BAs are now responsible for complying with nearly the same requirements as CEs, effective Feb. 18, 2010.

He believes that within a year of that date, CMS will likely start auditing BAs and putting them under a microscope the same way it has with CEs. To prepare, BAs should also review the compliance summary, he says.

“I think if you are a BA, you need be mindful of everything that is required, because I do believe that enforcement is being stepped up,” he warns. “I think we will see an audit of a big BA, maybe a transcription company or a practice management company, so that CMS can show that they are out there” reviewing BAs as well as CEs, he says.

If in fact business associates such as transcription service providers will be expected to adhere to the same requirements as covered entities--including mandatory encryption and employee background checks--the impact this will have on the MT industry is going to be enormous. The days of small-time MT operations may well be numbered, and government regulation will be the reason why.

Here are the meanings of the clue words and the answer to the mystery:

Chandler from the TV show "Friends", cherries - Chandler's last name was Bing, which is also a variety of cherry. Bing is the name of a search engine.

Pub Med, searching, racing Alaskan sled dogs, third entry, Willard Williamson, Royer McKenzie, Davis Payton - Searching for "pub med" on the search engine Bing directs you to http://www.ncbi.nlm.nih.gov/PubMed/. Searching in PubMed for "racing Alaskan sled dogs" returns several entries. The third search entry refers to a study of the use of famotidine in racing Alaskan sled dogs, authored by Willard, Williamson, Royer, McKenzie, Davis and Payton.

drug store - A reference to the drug famotidine

pud - PUD is an abbreviation for peptic ulcer disease, which is treated by famotidine

helicopter - A reference to Helicobacter pylori, the primary cause of peptic ulcer disease

small drainage canal - A reference to the small intestine, where peptic ulcers are often found

glanced - Sounds like "glands"

slippery substance - Mucus

name - The name of a gland in the small intestine that produces mucus.

And the answer is........Brunner!

Here is the mystery once again, only this time with key "hint" words underlined.  The hint may refer to either the meaning or even the sound of the word.  If you think you know the answer, please feel free to post it in the comments section below.

I had a weird dream last night. In my dream, I saw that guy Chandler from the TV show "Friends" walking down the street carrying a bowl of cherries. I went up to him and asked him if he knew how to get to a bar I'd heard about called Pub Med. He gave me directions, and once I got there I looked through the window, searching to see what was inside. On a flat-screen TV hanging on the wall I could see some kind of program about racing Alaskan sled dogs, which I thought was kind of weird. As I continued to watch the screen, the camera zoomed in on the third entry in the race, and graphics displayed the names of the team members, Willard Williamson, Royer McKenzie and Davis Payton.

Then I woke up. Chuckling to myself as I thought about the odd dream I'd just had, I remembered I needed to stop by the drug store. Just then, my dog jumped up onto the bed and in one flying leap landed on my belly. "Rocky, you pud, what do you think you're doing?" I laughed as I scratched his ears.

Suddenly I heard a tremendous explosion outside, and I jumped out of bed and ran to the window. To my amazement, I saw that a helicopter had crashed into a house located near a small drainage canal a few hundred yards from my own home. I frantically ran outside and raced toward the burning residence.  I glanced through the front door and saw the owner of the house lying on the floor, covered in some kind of slippery substance.

WHAT WAS THE NAME ON THE MAILBOX?

We MTs pride ourselves on our medical knowledge as well as in our research skills. Here's a fun little test of those skills; see if you can solve the mystery!

I had a weird dream last night. In my dream, I saw that guy Chandler from the TV show "Friends" walking down the street carrying a bowl of cherries. I went up to him and asked him if he knew how to get to a bar I'd heard about called Pub Med. He gave me directions, and once I got there I looked through the window, searching to see what was inside. On a flat-screen TV hanging on the wall I could see some kind of program about racing Alaskan sled dogs, which I thought was kind of weird. As I continued to watch the screen, the camera zoomed in on the third entry in the race, and graphics displayed the names of the team members, Willard Williamson, Royer McKenzie and Davis Payton.

Then I woke up. Chuckling to myself as I thought about the odd dream I'd just had, I remembered I needed to stop by the drug store. Just then, my dog jumped up onto the bed and in one flying leap landed on my belly. "Rocky, you pud, what do you think you're doing?" I laughed as I scratched his ears.

Suddenly I heard a tremendous explosion outside, and I jumped out of bed and ran to the window. To my amazement, I saw that a helicopter had crashed into a house located near a small drainage canal a few hundred yards from my own home. I frantically ran outside and raced toward the burning residence.  I glanced through the front door and saw the owner of the house lying on the floor, covered in some kind of slippery substance.

WHAT WAS THE NAME ON THE MAILBOX?

If you think you know the answer, please email me with your guess and how you arrived at it.  Please email me rather than posting your guess as a comment here, so as not to spoil the fun for other would-be detectives.  I'll give the answer in a future blog post, as well as the explanation of all the clues. 

"Having experimented with purely automatic speech conversion, SpinVox decided early on in its development that because its voice to text service converts real-life, dynamic and fast-evolving language and messages that we use and exchange every day (known in the industry as ‘free form speech'), it was essential that the system had the capability to evolve at the same rate, converting the latest words, phrases, brand names and colloquialisms to ensure a high level of accuracy. This is why it describes the system as ‘live-learning'," the company said.

Live-learning combines SpinVox's "rapidly evolving state-of-the art technology with human quality control and training," to convert its messages. This seems to be an admission that humans are used in the message conversion process, and is nothing new from SpinVox, but it is still not a clarification on the extent to which humans are used. Although the company does admit that it works with five call centres for quality control purposes.

As the telecoms.com article points out, the patents filed by SpinVox co-founder Daniel Doulton in 2004 don't help the company's argument much. From the abstract of US patent application 20060223502: "One of the networked computers plays back the voice message to an operator and the operator intelligently transcribes the actual message from the original voice message...The transcribed text message is then sent to the wireless information device from the computer. Because human operators are used instead of machine transcription, voicemails are converted accurately, intelligently, appropriately and succinctly into text messages (SMS/MMS)."

Elsewhere in the SpinVox statement can be found this nugget:

"Quality Control agents are an important part of the SpinVox service because their constant minute-by-minute input actually improves the quality of text conversions in a process we call `live learning`. The technology is a bit like a human brain, in that, the more it is exposed to input, the more it learns.

"This process has helped us improve our accuracy massively. Since its inception in 2007, the technology has improved to the extent that the system requires only two per cent of the input it required just two years ago and can even now predict more than 99 per cent of what most people speaking in English or Spanish will say next.

Maybe it's just me, but the phrase "constant minute-by-minute input" on the part of live agents sure sounds like they're very intimately involved in the transcription process, the company's emphasis on the technology aspect notwithstanding. Also, I'd like to hear other speech recognition technology developers' take on the notion that SRT can accurately predict "more than 99 per cent of what most people...will say next." I'm not even sure what calculations you'd need to use to come up with that figure in the first place.

But when it's all said and done, even if the company's claims about the technology's potential turn out to be accurate, the undeniable fact is that without the intervention of skilled human knowledge workers, the whole process falls apart. 

As always.

The Spinvox website makes this statement (emphasis mine):

How does it do it? It captures spoken words and feeds them into a Voice Message Conversion System, known as ‘D2' (the Brain), and spits them out as text content.

So D2's pretty smart. It's bound to be, as D2's a combination of artificial intelligence, voice recognition and natural linguistics. But it also knows what it doesn't know and is able to call on human experts for assistance. It learns all the time about how we speak, and what we say, from the mundane to the ridiculous and so is able to convert what you mean to say.

"Able to convert what you mean to say." Isn't that the holy grail of speech recognition? Wouldn't it be something if technology could really do that?

Only problem is, it can't. While Spinvox won't divulge exactly what percentage of its transcriptions are done by humans rather than computers, the BBC is reporting that its sources say transcriptions at one call center in Egypt were done "100% by people." According to Kareem Lucilius, who says he worked at the call center for six months, "We heard the message from the very beginning to the very end. Love messages, secret messages, messages with sexual content, even people threatening to kill each other." Another source within the company has told the BBC that the vast majority of messages are converted to text by humans rather than by speech recognition technology. 

The Spinvox story is certainly interesting in its own right, but what I thought was particularly remarkable about this story was a quote (second link above) from a solutions architect at Nuance, obviously a competitor of Spinvox. John West is quoted as saying, "In Nuance's view, this task [transcribing phone dictations] will never be able to be totally automated in the near future. You cannot control the person leaving the voicemail, or the environmental factors.  Spinvox is offering something that is impossible to deliver now."

Oh?

So let me get this straight. Someone who works for Nuance, home of Dictaphone, eScription, and Dragon Naturally Speaking, is admitting that not being able to control either the person dictating or the environment in which they dictate means that transcription via speech recognition technology will "never be able to be totally automated in the near future." In other words, as long as doctors are being told by SRT salespeople that they can continue to dictate "just like they always have" in busy corridors, noisy offices or in cars with the windows open, MT editors can rest easy that there will always be a need for our services in the foreseeable future.

Good to know.

For MTs who worked on production for MedQuist between 11/29/98 and 8/11/08, and did not exclude themselves from the settlement class, a web page has been set up on the AHDI website to allow you to select one of the available program offerings:

• Complimentary individual professional membership in AHDI.
• One year’s subscription to the Benchmark KB product.
• Two online continuing education courses; including our credentialing prep and multi-specialty courses.
• Education Product Bundle including four of our electronic educational CDs.
• Six month access to our online creditworthy web presentation library.
  

According to the website, all eligible participants should have received a letter by the end of July with a username and password needed to log in and select one of the above options. Individuals who believe they are eligible for the settlement but do not receive a letter should contact member services toll free at 800-982-2182 or via email at ahdi@ahdionline.org for eligibility verification.  

Answers to frequently asked questions about the MedQuist settlement can be found here.

The story of Seattle Children's Hospital's transition to SR editing is one that is quite familiar to me, having been involved in a number of such endeavors personally and speaking with many other MTs and managers who have done likewise.  One of the unfortunate shortcomings of this article is that it makes little mention of the difficulties likely to be encountered by all parties involved when making this kind of transition, other than a passing comment that "Some...MTs picked up [SR editing] skills faster than others..."  There is no discussion, for instance, of the problem of dictators who, for one reason or another, simply are not good SR candidates. 

As a matter of fact, the authors of the article assert that the percentage of dictators whose dictation is voice recognized "is now stabilized at about 80 percent" and that "the other 20 percent can be attributed to our residency program, in which we have providers who are new to the system rotating in and out every few months."  This leaves the impression that 100% of the permanent physicians' dictations are being successfully recognized by the system.  If this is true, I suspect the eScription recognition threshold for this facility has been set fairly low, as in my experience with the eScription platform, I've never seen this level of successful implementation, ever.  I certainly am willing to stand corrected, if there are any eScription users out there who can provide evidence to the contrary, but until then I view this claim with skepticism.  The problem with setting the recognition threshold too low in order to recognize all dictators, in my experience, is that a significant percentage of the resulting SR drafts are going to be so bad it will take longer to edit the report than to simply type it from scratch.

Also of interest in the article, the authors report after transitioning to SR editing in January 2008, Seattle Children's SR editors have realized a 61% overall increase in productivity.  This is not out of line with what I've seen across the industry.  The article's authors also state that the hospital has been able to reduce outsourcing from 30% to 10%, with the 10% necessary only because of an increase in dictation volume.  The hospital has also been able to eliminate chronic overtime for their MT department.  This supports a contention I've been making for years now, which is that a good SR platform will pay for itself by virtue of increased productivity alone, without the need to reduce MT editors' compensation.

The article does not mention how or if editors' rate of compensation has been adjusted as part of the transition to SR editing.  This consideration is probably of more concern to MTs working on production, and I get the impression that the Seattle Children's MTs are employees working for hourly wage.  But for MT editors working on production especially, the level of increased productivity is only half the story; it's how their rate of compensation is adjusted that makes all the difference.  For instance, in this particular situation, if editors worked on production and their rate of compensation had been decreased by 50% (that is, cut in half), a common occurrence across the industry, MTs would have realized a net loss in total compensation because they aren't seeing a 100% (i.e., doubling) of their productivity.

I don't mean to give the impression that I'm opposed to the use of SR technology in the healthcare industry.  On the contrary, I believe SRT can be a great boon to MTs and enable them to be more productive while saving a lot of physical wear and tear on the hands and wrists.  The technology isn't the problem.  My concern relates to how the technology is marketed, that is, whether or not the people who write the checks have realistic expectations going in, and how compensation is tied to the use of the technology.  Skilled medical transcriptionists who make the transition to SR editing should not be penalized with decreased compensation in order to help pay for a technology platform that was sold with unrealistic expectations.

Having said that, of course, you'll need to check them out for yourself to see if any of them will meet your needs. There are certainly some very good commercial text expander applications on the market that may have features the free programs don't have, so you'll need to comparison shop to determine what will work best for you.

In any case, when it comes to increasing productivity in the transcription business, few tools can offer working MTs more bang for the buck than a good text expander. I've accumulated literally thousands of typing shortcuts over the years, and I wouldn't dream of working without them. Certainly it takes a little extra time in the beginning as you create your own library of shortcuts, but you'll more than make up for it in increased productivity in short order.

Whether you decide on a free or commercial text expander, it's an investment in yourself that's guaranteed to pay big dividends - and doesn't THAT sound good these days!

The quality of your dictation affects the accuracy and turnaround time of your transcriptions which directly impacts patient care and reimbursements. Your practice can benefit greatly by improving the precision of your dictation skills. Good dictation will bring you savings, as well: poor dictation consumes time and labor, increasing overall documentation costs. Finally, quality dictation can even help you legally: fewer transcription mistakes caused by poor dictation equate to fewer errors in patient care.

By incorporating the following top 10 tips for successful dictation, you can accelerate the time it takes medical transcriptionists to learn the style of your dictation, as well as improve their accuracy - all the better for you to run an efficient and high quality medical practice. A win-win for all.

The tips include:

1. At the start of your dictation, gather any papers, reports that you might need for your reference.

2. Dictate as if you are speaking to the patient in an exam room, speaking clearly so the Medical Transcriptionist will understand you without error.

3. Speak at a steady pace and not too loudly or softly. Keeping the recorder approximately 8-10 inches from your mouth will help improve clarity. Always move your face away from the recorder to sneeze or cough.

4. Minimize noises including the TV or radio, eating, drinking, chewing gum, shuffling papers, opening drawers, rearranging your desk or making loud noises as they can be very distracting to the medical transcriptionists. Likewise, do not dictate in a crowded room. The background noise is distracting and you may be sharing protected health information inadvertently.

5. Avoid multitasking while performing dictations. Use the pause button if you would like to take a sip of water or sort out documents. Do not dictate while driving. The sound quality is usually poor, not to mention that it is dangerous.

6. Identify yourself and state what type of report you will be dictating. Detail any special instructions at the beginning of the dictation. State, and then spell full details of information such as the patient's full name and proper mailing address on letters.

7. During the dictation be as specific as you can with spelling, phrasing, formatting and ‘normals'. Spell the names of patients that you think the Medical Transcriptionist may not understand (i.e. ‘Amy' spelled instead as ‘Aimee'), as well as local names or cities. Clearly spell words that may not be commonly used in the medical field, including new pharmaceuticals or treatments and unusual words representing diseases, drugs, or procedures not normally found in the mainstream of your daily work or specialty. Use the same phrases in each of your report types and follow the same order of headings whenever possible. Furthermore, be specific when inserting "normals". If you need to change any part of the normal, please indicate exactly what information the medical transcriptionist should delete and where to insert changes.

8. Include punctuation, especially when starting new paragraphs, and include "open" and "close" quotation mark instructions.

9. Avoid using a lot of "ahhhs," "ums," "ers" and "uhhhs." They can be confused for the letter "a".

10. While cellular phones are convenient, the sound quality is usually not ideal. Land lines will give the medical transcriptionist a better quality recording.

I must say it's refreshing to see a transcription company publicly acknowledging that the quality of dictation, which is the dictator's responsibility, has a direct impact on the accuracy, timeliness, and reimbursability of finished transcripts. Working MTs have long been pressured to produce accurate work on short turnaround time, but the fact is the quality of the original dictation has a lot to do with how well MTs can do their jobs. Whether or not this white paper will have any discernible effect remains to be seen, but I definitely give MxSecure kudos for making the effort.

Are there any other tips you'd like to give dictators if you could? Please feel free to comment.