Medical transcription schools and the FTC

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.

AHDI interactive - kind of

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• Medical transcription and the miracle solution
• What is the medical transcription business?
• Internet marketers and medical transcription
• I’m not paid enough
• Speaking of change – changes at MT Desk and MT Chat