Wednesday, May 23, 2012

Mandatory Medical Transcription Credentialing


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Much has been said lately about the AHDI House of Delegates resolution last August to support mandatory credentialing for anyone who accesses patient health information. That would mean mandatory credentialing for medical transcriptionists. While many do feel it may be a good idea, I want to explore this a bit more. How does it come about? In the end, I believe it's about having a compelling story.

What's the Compelling Story?

AHDI has started a campaign for speaking to legislators and talking about the need for mandatory credentialing. So what's the compelling story that might make that happen? Without a compelling story of why this should happen, I don't see legislators buying it. The lobbying power of our industry just isn't that strong.

A compelling story must give a reason for doing something. It should have solid, logical facts behind it. It should also show a benefit for doing something. If you think about the story behind something like the Amber alert laws, you can see a compelling story. Children were being kidnapped. The facts were pretty easy to put together. The benefit? If notices were put out faster, perhaps the child could be found faster and returned home with less harm done to them. A compelling story. So what's our compelling story? Get out your thinking caps here because I want to challenge your thinking a bit. I'm putting on my devil's advocate hat as I believe these are tough questions we need to have answers for.

Patient Safety

We can stand up and loudly proclaim "it's health records, it is the patient's story! Surely something of that importance should have a credentialed person working with it to assure correct information and patient safety!" The mantra of patient safety is a big one in the healthcare industry. Perhaps attaching to that would help the cause. If we use this one, we also need to be prepared to explain what kind of harm has been done because of a medical transcriptionist who wasn't credentialed. I'm just not sure we have that data. Because so much of health care documentation is done after the fact, it's unlikely to get anyone to really believe that the documents were used in real-time to provide patient care. In addition, there's documentation out there where we have loudly proclaimed that no documentation is complete until it is authenticated by the physician who dictated the report. If that's the case, isn't it the physician's responsibility to be sure that what is reflected is accurate? In addition, with the move to using medical scribes to document healthcare encounters, we now have an entire industry that has no credentialing process and no standards of practice. If they can do that successfully, where's our compelling story?

It's all About Privacy

The argument could be made with all of the new regulations from HIPAA and the HITECH Act that the information is more secure with a credentialed person. After all, that knowledge would be a part of what is tested in the credentialing process. Hmmm, but what about the HIPAA rules that say all persons must have training and education in privacy? And while the HITECH Act is new, HIPAA certainly isn't. Those rules became effective five years ago and we weren't banging the drum of privacy needing a credentialed workforce at that time. Was the MT who threatened to release medical information over the Internet several years ago credentialed? Have any of the data breaches that have been reported been by a medical transcriptionist, and if so, was that person credentialed? I frankly don't know the answer to that. So, where's the compelling story here?

It Will Save Money in Health Care

In The Case for a Credentialed Workforce published by AHDI in 2007, the case is made that having a credentialed workforce can save money. Here's the quote:

Every time a report is transcribed by an MT with a low level of knowledge and interpretive skill,

the healthcare system as a whole takes the following risks:

• That the MT will misinterpret key clinical data being dictated, resulting in the potential for this to be overlooked by the provider at the authentication point, and for the error to become part of the patient's permanent record, upon which ongoing care decisions are based.

• That the MT will miss or fail to hear critical information, resulting in omitted words or phrases that the provider may not recognize are missing at the authentication point.

• That the MT will fail to recognize dictated errors and inconsistencies and therefore neglect to flag them to the dictator's attention, again with the potential of those errors becoming part of the patient's permanent record.

• That the MT will struggle with challenging dictation or unfamiliar terminology, leaving blanks in the record that have to be routed back to and filled in by the provider or forwarded to a QA department for review and correction - processes that suspend the forward progress of that record.

All of the above scenarios represent widespread impact and immeasurable cost to healthcare on a daily basis. How much does it cost a healthcare facility for records to be suspended in QA and correction rather than being coded and processed for reimbursement? Great attention is often paid to how long dictated reports sit on the dictation system before they are transcribed, but how closely are healthcare facilities and providers watching the delay between transcription and the release of that document for continuity of care and reimbursement?

What seems to be missing is how often those things happen with CMTs and RMTs vs. those who don't have a credential. There is also no discussion about whether it may cost more to employ a credentialed MT compared to one who isn't credentialed.

It's About Efficiency

One thing we have to be prepared to answer is how will this increase efficiency in health care? As leaders speak to legislators, they often share their own story. That will lead to questions about whether they are credentialed themselves. Then we'll go to the bigger question. How many MTs are there currently? Estimates several years ago were at around 250 to 300 thousand. The next logical question will be and how many of those are credentialed? The last numbers I saw showed there were around 3,000 CMTs, and I'm not sure how many RMTs. Still that represents less than 1% of the workforce, allowing for a growing workforce (based on the US Department of Labor information that projects growth in this industry through 2012). Will requiring a credential lead to greater efficiency, or will it lead to the industry scrambling to figure out what other ways they can utilize to get the documentation done? Again, what's the compelling story?

Is There a Compelling Story?

When speaking with legislators in an attempt to make this kind of change, you have to have data. You also need that compelling story about why it's necessary. Do we have a compelling story or simply a wish to see this happen?

What's your take? What IS our compelling story here?

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