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In the internet marketing world, there's what's known as a flog. A flog is fake weblog. In other words, it looks like a real person writing about real experiences – while promoting a product.

In a prior post, Internet Marketers and Medical Transcription, I noted how medical transcription is an attractive target for internet marketers. What I didn't talk about was flogs.

In the medical transcription world, a flog might look like this:

Hi, my name is Jill. A couple years ago, I was desperate for work I could do at home to make some extra money for our family. A friend of mine told me about medical transcription, so I checked it out and found out it's a great work-at-home career for people like me. I went to XYZ Transcription School and got my certification. When I graduated, I found a job right away and now I'm making extra money while my children are in school. I don't have to pay for daycare, either – by the time they come home from school, my work is done and my house is clean! If you want to work at home, you should sign up today to go to XYZ Transcription School and become a medical transcriptionist, just like I did!

What makes this a flog?

What would make this a flog is if the person who owns the site and posts the entries isn't named Jill, didn't go to XYZ Transcription School (or any other transcription school) and/or isn't working as a transcriptionist – and never has. The site exists solely for the purpose of attracting people who are searching for medical transcription careers, work-at-home careers, etc., convincing these people that medical transcription is a wonderful career and that XYZ Transcription School will do a fabulous job of preparing them for this career – then referring them to XYZ.

Why would they do that?

Because XYZ Transcription School will pay them $$$. This is known as an affiliate arrangement, where you have the advertiser (the MT school) and the publisher (the web site). Depending on the program, they will get paid for a lead (an e-mail address, which is why many of these have a "free" giveaway that requires signing up for a mailing list), a phone call to the school and/or a sale. Most of them pay based on a sale and the amount can be substantial. For example, FutureMT pays $160 when an affiliate site sends them someone and a sale is generated.

Don't get me wrong – I'm all for generating revenue. And there's nothing illegal or immoral about affiliates or affiliate ads.

However, not only are flogs immoral (in my opinion) – they are also illegal. And they always have been.

Pity the poor FTC, having to police the internet.

Example of a suspected flog

I came across this site that just practically sat up and announced  "I am probably a flog" to me. Somehow, I really doubt that "Kate Delaney" is really someone who went through the program and now works as an MT. If you send her e-mail and ask her questions about FutureMT, getting a job as a new graduate, is she hiring, who does she work for, how does she like it – you aren't likely to get an answer. Even though her contact page gives an e-mail address and tells you to contact her if you have questions about a medical transcription career, an e-mail I sent 2 weeks ago from a gmail.com mail account still hasn't been answered. Maybe she's busy transcribing.

Or – maybe she's busy doing other stuff because she isn't actually Kate Delaney. Look who owns the domain name: Beth Stefani of Lariat Group. (I'm going to start the timer after I post this and see how long it takes Beth Stefani to make this registration private.)

Now, it's POSSIBLE that "Kate" hired Lariat Group to buy her domain name and manage it for her because teaching businesses how to manage blogs and be profitable is one of the services offered by Lariat Group.  I would hope that if a company like Lariat Group is advising "Kate," they would certainly make sure she complies with the FTC requirements for bloggers and endorsements. But it appears to me that Ms. Stefani gains her expertise for consulting through "hands-on experience running her own network of sites," so I suspect there is no Kate Delaney and that this is actually a site in said "network of sites."

Again let me reiterate – I have absolutely no problem with people putting up websites and trying to make money. Hell – I do that. But in my opinion, what Beth Stefani is doing at this site is immoral. And I guess the FTC agrees with me, because it's also illegal.

FTC Regulations for Bloggers

False advertising has always been illegal, anywhere. The FTC has recently updated its guidelines because flogs have been a real problem on the internet. For one thing, they're lucrative. Imagine if "Kate" can get 10 people a month to sign up with FutureMT – she made $1,600. Heck, most legitimate transcriptionists I know would be happy to create a REAL blog for that kind of money!

There's just one catch and that's the FTC's guides concerning the use of endorsements and testimonials in advertising.

When the advertisement represents that the endorser uses the endorsed product, the endorser must have been a bona fide user of it at the time the endorsement was given. Additionally, the advertiser may continue to run the advertisement only so long as it has good reason to believe that the endorser remains a bona fide user of the product.

What does "bona fide use" of an education mean? It means "Kate" not only must have actually done what her "blog" says she did (attended the FutureMT program and graduated), but she must also be working as a medical transcriptionist in order to endorse the product, which is an education that allegedly prepared her to be a medical transcriptionist. Even if "Kate" actually did attend FutureMT, she cannot endorse the product until she is working as an MT. And when she is no longer employed as an MT, she is no longer "using" the product of a medical transcription education.

One of the other requirements the FTC has clarified is that a blogger must disclose material connections with an advertiser, and that disclosure can't be hidden somewhere in the small print – it has to be easily apparent. Even if "Kate Delaney" is a real person who actually graduated from FutureMT and is working as a medical transcriptionist, there is no disclosure anywhere on the site.

When an advertisement is clearly an advertisement – such as a banner ad or Google block (who can possibly mistake those for anything but an ad??), no disclosure is required. Endorsements and testimonials are where people really seem to get into trouble. This is nothing new – the same rules apply for print ads and endorsements, infomercials, television and every other kind of media. For some reason, bloggers thought the rules didn't apply to internet advertising!

Can the advertiser be held responsible for what its affiliates do?

Let's look what the FTC says in their guide:

In order to limit its potential liability, the advertiser should ensure that the advertising service provides guidance and training to its bloggers concerning the need to ensure that statements they make are truthful and substantiated. The advertiser should also monitor bloggers who are being paid to promote its products and take steps necessary to halt the continued publication of deceptive representations when they are discovered.

That looks like a yes to me!

Last but not least – why do I care?

As noted in my last blog post, people who want to join the work-at-home workforce seem to be like cannon fodder – or lemmings. These flog sites are run primarily by people who make their living off affiliate sales and who know how to get to the top of the search engines so they'll be found. They don't care if someone scrapes and saves and spends their last dime to pay the tuition, then scrapes and lives hand-to-mouth during the entire time they complete the course, or that they are depending on the money they will make once they complete it and start their career. All they care about is getting more people to their site because it's a numbers game – more targeted traffic translates to more sales. And that's really what they care about – the sale. You won't find them promoting the best schools – you'll only find them promoting the schools that offer the highest dollar amount to their affiliates. By the time the prospective MT finds it's next to impossible to get that dream job, the affiliate has been paid – and isn't answering e-mails. They also don't care what this does to the industry and how it drags all of us down. First, it was "matchbook schools" we fought – now, it's internet marketers looking for the big-dollar affiliate payouts. I've made a good living from medical transcription all these years. No, I don't recommend it for anyone because of changes in the industry since I started – but I also acknowledge there are people who don't have as many options as I do, who really do need a job that's portable or that they can do at home, for a variety of reasons and not all of them having to do with having children. For those people, medical transcription may still be the best option. I just hate to see them given information based solely upon how much money the person disseminating the information will get if they can make the sale. Even if we believe in "let the buyer beware," the FTC has undertaken these guidelines to protect consumers. And for as long as I give even a small damn for the medical transcription industry, I will continue to try and not only call these people out when I find them, I will also try to outrank them in the search engines so that prospective medical transcriptionists come to sites where they are talking to real medical transcriptionists, not fake ones trying to make a sale.

Now for the disclaimer!

I am not 100% positive that the above-referenced site is a flog, I only suspect it is a flog. Heck, it may be legitimate. I will publicly retract my allegations if Kate Delaney will contact me with proof of her identity, a certificate of graduation from FutureMT and verification of current employment as a medical transcriptionist. As with everything else at MT Exchange, this is just my opinion based upon the facts availableto me at the time of publication.

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I have to admit when I saw the title of the latest blog at the AHDI Lounge blog, I was intrigued – so they get points for an interesting title.

Is the medical transcription profession doomed?

Just reading the title, I thought maybe AHDI was finally going to take off the rosie-colored glasses they wear in public. During the whole decline of the industry, they’ve insisted that there’s a place for medical transcriptionists in whatever new world health information documentation evolves to. (The other blog post there, Doctors weigh in on the use of scribes, is another worthy of its own separate rant.) So I eagerly went to read the entry, thinking maybe maybe AHDI is going to come out of the closet about the future of medical transcription.

Boy, was I disappointed when I read the blog entry. And surprised not only at the apparent cluelessness at what practitioner MTs (their base membership) go through on a daily basis, but the direction AHDI seems to be willing to take with the tone of this blog entry.

First of all, is it really standard practice for MT recruiters to not respond to those who are applying for jobs? Even if the applicant bombed the test, common courtesy would be to at least thank them for the effort, wouldn’t you think?

Is it really standard practice for the World’s largest professional association representing and advocating for healthcare documentation professionals (MTs, editors, and QA coordinators) (that’s what their Twitter profile says) not to know that yes, indeed, this is standard practice in the industry? That every day, recruiters receive hundreds of applications, solicited and not, and can’t possibly respond to all of them? That MTs take tests all the time – and never hear back a peep from the testing company? That common courtesy isn’t so common? That sometimes recruiters not only don’t know what they’re talking about, but they lie, don’t give direct answers to questions, set up phone calls they blow off, and are even downright rude?

Not that I think that’s a huge factor in what is happening to “doom” the medical transcription industry.

But here’s the part that blew me away:

It’s a tad ironic for someone so concerned about communication skills to criticize someone for not being “atriculate” and having poor “dictation.” And as anyone knows who has participated in online MT forums for any length of time, this scenario is all too common.

Let’s put aside for a moment that anyone who has participated in online MT forums for any length of time should know that the common response to this: I’m not at work so spelling, grammar and punctuation aren’t a priority. (And since I’m putting it aside for a moment, that’s all I’m going to say about it.)

How professional is it for the world’s largest professional association to slam a medical transcriptionist for spelling and grammar errors in an online forum? And a forum that isn’t even theirs?

AAMT/AHDI has never seemed to understand that nonmembers are still potential members and that’s demonstrated again in this blog post. It’s probably not a good idea to alienate your prospective membership base if you expect to recruit and grow – unless, of course, AHDI is happy with the number of members it currently has. However, by claiming to be the world’s largest professional association representing and advocating for healthcare documentation professionals (MT’s, editors and QA coordinators) it’s painting the MT world with a very large brush. I guess it wouldn’t sound so great to be the world’s largest professional association representing and advocating for a very small percentage of healthcare documentation specialists – but it would be a more accurate representation.

It’s one thing for a blogger with no affiliations to blow off steam about whatever they want. Heck, I do it all the time! But I don’t represent the professional association. Matter of fact, I don’t represent anybody but me. Call me old-fashioned, but the official blog of the professional association should be – well, professional! And in my opinion, being professional means you don’t slam MTs posting in forums for their spelling and grammar, even if they are anonymous.

AHDI had an opportunity to focus on something that’s wrong in the industry and actually advocate for the practioner MT – and they blew it by losing focus and attacking the messenger.

So if we’re looking at factors that doom the medical transcription profession, I have to say – AHDI, look at the mote in your own eye.

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This all started with a query at MT Chat, which asked (in part):

Can anyone tell me if it makes a difference which online program you use? I’ve heard that potential employers look for someone that’s been trained by an AHDI approved program. But when I asked Future MT, a non-approved program, they said that their program was as good as the others on AHDI’s list but you have to pay to get on that list and they simply choose not to, so as to pass that savings on to the student.

I found that an interesting response from FutureMT because it’s wrong on so many levels. Well – I suppose it makes sense if you’re trying to justify to prospective students why you aren’t on that list. I wonder how many people fall for it (probably quite a few). Because if you go read that discussion at MT Chat, you’ll see that Mike DeTuri broke down the cost per student based on XX number of students and it’s pretty negligible. And aside from that, schools don’t pay to get on the list, they pay a fee to apply to be on the list – big difference. A school can pay the fee and submit the required information and if they don’t meet the requirements, they still aren’t approved – and they don’t get a refund of their application fee.

So I moseyed on over to the FutureMT web site to see what their web site says about them. And I discovered something else interesting about FutureMT:

Future MT is not an accredited medical transcription course as a university within the state of incorporation, but rather a nationally recognized online education course using similar guidelines of major Universities.

When it comes to voluntary programs designed to evaluate a school program, FutureMT doesn’t seem willing to waste its money, as it isn’t accredited by the state of Florida, where the company is based, either. Not unlike the transcription sites that all claim “best, fastest, cheapest,” making a claim of nationally recognized online education course is pretty easy. It can’t be verified, certified or accredited – but it sounds good! (Maybe I should change the MT Exchange tag line to nationally recognized online blogger.) There are a number of nationally recognized accreditations for distance learning programs, including the Distance Education & Training Council (DETC), Accrediting Council for Independent Colleges & Schools (ACICS) and Accrediting Commission of Career Schools and Colleges of Technology (ACCSCT). Accreditation by any one of these would at least give proof to the claim of nationally recognized online education.

In fact, this is one of the requirements to become an AHDI-approved school:

The school/program must be accredited or licensed through a governmental body.

So in terms of as good as, strike one for FutureMT.

What I like is the consistent theme: we’re saving money for our students!

Another benefit of Future MT’s course is that we do not have the large overhead needed to run a college, so we are able to pass those savings to our students and offer the same course at a more affordable cost.

I don’t know how prospective students read this, but it makes me wonder whether they have other cost-saving measures that might be cutting corners a tad too close – you know? Like – instructors. Like – curriculum.

Speaking of which…

Another requirement for AHDI approval is that the school must follow the Model Curriculum for Medical Transcription. And it’s really difficult to tell from the FutureMT website exactly where their coursework comes from.

The book Future MT uses is written by the staff of Health Professions Institute, which is the top name in the field, and extremely reputable. In fact, the founder of the American Association of Medical Transcription (AAMT) also founded HPI. Their materials are used widely among the most respected institutions.

As far as I can tell, the coursework (curriculum?) consists of handing you a book that can be purchased straight from Health Professions Institute (HPI) and the SUM Program practice recordings, which can also be obtained directly from HPI.

But wait – there’s more!

You get unlimited live mentoring with experienced MTs! I’m not hearing the word “instructor” or “teacher” there. For all I know, their definition of an experienced MT is someone with 2 weeks’ experience.

Students, at the appropriate time from Future MT instructors will be given access to the transcript keys and compare their work to the keys in a split-screen format, giving them immediate feedback on their errors.

Oh look – NOW we have “instructors.” Let me tell you something about giving students answer keys – they don’t learn much and it renders the rest of the exercise useless once someone has the answers.

But wait – there’s more!

I felt this part was worthy of a screen shot. Please comment if any of this makes sense to you.

Huh?

And in the FAQ titled How Long Will the Course Take to Finish?, I found this gem:

Future MT’s medical transcription training focuses on helping students find work quickly instead of spending more time training.

Yes, we certainly wouldn’t want future MTs to spend too much time training! Let’s focus instead on getting a job!

But wait – there’s more!

There’s an Employment Service!

And it’s part of the Guarantee!

So let me see if I understand… if taking a list of potential employers and bombarding them with resumes for 60 days doesn’t elicit any offers of employment – they’ll help you do it for another 12 months, hoping for a different response? (What are their affiliate transcription companies, anyway? I hope this isn’t just a list of transcription services they scrounged off Google.) Does everyone here understand the definition of insanity?

And every flippin’ page at FutureMT ends with this:

I have to wonder how much value there is to that guaranty when I’m getting bombarded with messages from graduates who can’t get a job. Money back? You can claim it within the first 30 days of enrolling. Of course, by the time you graduate and can’t get a job, the 30 days is long past.

Do I really need to keep going? Unfortunately, there seems to be no limit to the number of people willing to be the fodder for cheap programs that will take their money, turn them loose – and then fill up my mailbox with pleas for help getting that elusive job.Which is why I keep blogging about it – someday, I’d like to believe my yammering made a difference.

I think it’s pretty clear that: (a) not all transcription schools are equal and (b) FutureMT is not as good as a school that is licensed or accredited by a governmental body and approved by AHDI. Let me be clear – I don’t think AHDI approval is the be-all/end-all – but it is a distinction, a step up and frankly, all we’ve got. Given that, I think it’s essential that the medical transcription community supports that program.

But that’s not all…

OK, I have to save the very best for last. This just had my jaw dropping. I went to the LINKS page at FutureMT, expecting to find links to MT resources and information. Instead, I found this:

Is it just me – or is this about the tackiest thing ever for a professional website? The only MT site listed there is one owned by FutureMT. I mean, really – credit score reports and satellite dish links on a professional site?

(Look for my followup article next week on Medical Transcription Schools and the FTC)

Teeny tiny disclaimer: Like everything else at MT Exchange, this is only my opinion. Take it for what it’s worth.

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Just in case you didn’t know, we are in the “healthcare documentation sector.” We still do medical transcription and we’re still called medical transcriptionists, but only because there’s no organized group <ahem> that’s been able to either decide what else to call us and/or make it stick.

However, medical transcriptionists everywhere can rejoice, knowing that AHDI now has a manual of ethical best practices available for us healthcare documentation sector workers.

And signaling that yes indeed, the practitioner member is once again not as important as the practitioner MTs themselves would like to think, there is no special pricing for practitioner members. Should you decide you can’t live without knowing why there’s a section for AHDI Code of Ethics and another for MTIA Code of Ethics, this baby will cost you a whopping $4,000.

Which is, I’m sure, just the start of the confusion.

After stating (very convincingly, I might add) that this is much, much less expensive than you’d pay if you put this together yourself or pay someone to do it for you (can you put a price tag on the AHDI Code of Ethics or the MTIA Code of Ethics? I think not), then setting you back on your heels with the $4,000 price tag – they soothe your ruffled feathers by letting you know that everybody except practitioner members can get this for less than $1,000.

Damn – I sure hope practitioners don’t actually need this for anything because at a reported average annual income of $30,000/year, the cost of this is just over 13% of an MT’s annual pay.

The pricing on this package (and possibly even the package itself) signals that not only is AHDI still floundering when it comes to offering anything of value to this membership group, they also don’t mind spitting in their faces. Because just in case you missed the part where you’re paying more than anyone else, there’s this friendly reminder:

It’s comforting to know that Gold Members of MTIA – which I’m sure includes companies that could actually afford to develop this information inhouse – don’t have to pay a dime. I’m sure this contributes mightily to the credibility of the claims that the relationship between AHDI and MTIA is good for both. I wonder how many Gold level members are on the MTIA Board. Just wonderin’, that’s all.

Isn’t it nice to know that AHDI knows which side its bread is buttered on? I’m looking on their web site and trying to find some indication as to who they think is going to pay the dues to keep the organization afloat if they piss off enough practitioner members, which still constitutes the largest membership group. Maybe AHDI has given up trying to find something of value to offer to the practitioner members.

Since I’m never going to pay $4,000 (or, let’s face it, $250, $750 or $950) to actually take a look at this manual of ethics and best practices, I really shouldn’t can’t say much about the package itself. I am, however, going to latch onto the term production location transparency. It’s a whole lot catchier – and easier – than “where is this work being transcribed?” I guess I’m just going to have to wither away with curiousity as to the difference between AHDI’s code of ethics and MTIA’s code of ethics.

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This came up at the Restuvus MT forum. For some reason, people started e-mailing me (maybe because I live in California, maybe because I’m a loudmouth – hard to tell) and I decided to blog it because Restuvus doesn’t archive their conversations and this one should stick around for awhile.

I’m not going to go into the whole story or link to the original post (because it’s just going to move off the page and be lost forever anyway), but here’s the general idea. The original poster (OP) did some work as an independent contractor for an MTSO in California. The 1099 she received had, for some inexplicable reason, the correct name but the address on it was the MTSO’s address in California. She then asks how she proves she’s not a California resident so she doesn’t have to pay 7% income tax in California.

There are many things wrong with this. First of all, whoever did the 1099s needs to go back to tax school. The address of the person the 1099 is being issued to is what’s supposed to be on the 1099, not the address of the person they did the work for. My advice? Send the MTSO a letter requesting that the 1099 be reissued with the correct address and send a copy of the letter to the California Franchise Tax Board.

Second of all, the withholding being referenced doesn’t go into effect until January 1, 2010, and even then it doesn’t apply in this situation.

Beginning January 1, 2010, the state of California is requiring payers to withhold 7% tax on reportable income for non-resident workers. There are details and notable exceptions of course. Companies and individuals doing work in California needs to download the guidebook (PDF) and read it.

The state of California is, as most of us already know, broke and grasping at straws. It seems the purpose of this particular requirement is to make sure it captures revenue that has been lost due to not being reported. This law will most affect people who come to California from out of state, work for a short period of time, then return home. It targets California non-resident independent contractors specifically.

But here’s the catch: the work must be performed in the state of California. Which lets out remote workers because you aren’t actually located in California. You can work for an MTSO located in California on an account for a hospital in California, but as long as your butt is in a chair in Kansas or anywhere else that isn’t California, you are exempt.

Download the guidebook and read it. I find the horse’s mouth is always the best place to get information. And my husband (a CPA) says you should never take tax advice from anyone but a tax professional. (I’m sure he means this as a warning to me, should I be inclined to give out tax advice on this blog!)

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