I'm doing an RFP response for a client that involves calculating billing using the VBC (visible black character) and I just have to comment about this white paper put out by AHIMA and MTIA.
It’s important that anyone reviewing this document remember that it is a white paper, and a commercial one at that. Wikipedia notes about commercial white papers: “These types of white papers are almost always marketing communications documents and are designed to promote a specific company's solutions or products as it relates to the issue or topic examined. As a marketing tool, it is important to note that these papers will always highlight information favorable to the company authoring or sponsoring the paper while minimizing any negative aspects related to the company's involvement with the issue, product or technology.”
It’s hard to keep in mind that the white paper is just exactly as Wikipedia defines a commercial white paper because it’s been touted as something else entirely. The way it’s being presented, I expected something – oh, objective. Instead, what I find is, to be blunt, horse puckey.
Let me start with the billing method principles from the white paper.

First thing - I scoured the white paper and I cannot find that verifiability, definability, measurability, consistency, integrity or reconciliation are defined anywhere in it. The authors of the white paper, then, don't impose upon themselves the same standards they wish to impose on the industry in their championship of the visible black character. Not defining these while still including them in the principles gives the Task Force (TF) the opportunity to check off the VBC as somehow being more “complete,” but at the same time obfuscates the very issue they claim to be clarifying.
Verifiability, definability and measurability are pretty self explanatory; consistency, integrity and reconciliation are not. In fact, this lack of definition makes it difficult to have a meaningful discussion about the comparative values (but I’ll try). Another thing that I’m having difficulty with is – aren’t verifiability and reconciliation the same thing? Again, a definition would have been helpful. Otherwise, this is just a table with six columns where quite possibly four or five would have been sufficient (albeit not as spiffy and important looking), where the reconciliation column seems to be there for the sole purpose of differentiating the VBC from an ASCII line count. In all other respects, the TF goes into great detail, so I’m somewhat perplexed as to why they would include “consistency,” “integrity” and “reconciliation” as though they are somehow important, and yet not explain what they mean and how they’re important.
For purposes of this discussion, I’m going to assume that “integrity” means the method is prone/less prone to padding/cheating, and that “consistency” means it’s a consistently accurate method. For the life of me, I can’t figure out how reconciliation differs from measurability so I’m going to ignore it.
Next, let’s look at the obvious subjectivity of the items the TF has checked off in comparing the VBC with other methods.
I ask anyone to explain how the gross line is not verifiable or measurable. What does make the gross line inconsistent is the fact that unless it’s defined as being a certain font, font size and with specific margins, the amount of text per line can vary widely. And yet the TF doesn’t even touch on this in the Section VI Explanation of Discussed Options! The only limitation they list is that all lines are counted equally, so that a line containing only one word is counted the same as a line that fills the entire width of the page. However, that isn’t the same as being not verifiable or measurable. In fact, gross lines would be more easily measured and verified than the VBC, since they can be counted down the left margin of the page (a process for which many people used a template back in the dark ages – but yeah, it was easily verifiable!). IMO, the TF indicating that the gross line is not verifiable or measurable is just an attempt to skew the results in favor of the VBC. I will agree that it isn’t consistent and it lacks integrity for the reasons I’ve given in addition to the limitation noted by the TF.
Now, I also have to remark on the one difference between the VBC and the ASCII line. In Section VI, the limitation of the ASCII line is: “Because spaces and tabs are included in this definition, it is not easy to count a document with the naked eye.”
First of all, who is going to count these with the naked eye?? In fact, in Section IV “Practitioner Prospective Benefits of Standardization,” the “naked eye” measurement is mentioned again, but then this statement is made: “Healthcare provider issues related to adoption of the proposed VBC standard are similar to those for vendors. The following should be considered… Automated line count software would need to be reviewed and updated.” So I ask again… who is going to count these with the naked eye? What makes “eyeball” verification more accurate than software verification? The TF doesn’t say, yet obviously they consider automated line count software important because they indicate it will need to be reviewed and updated. (News flash for the TF: That I’m aware of, commercially available software has been able to count by all methods discussed in this paper for at least the last ten years. If your vendors or facilities need to update software in order to count the VBC, you may have more problems than just transcription billing accuracy.)
Next, let’s look at the 65-character line. Verifiable? As verifiable as the VBC in that commercially available software will count format codes as either toggles (toggle on = 1 billable unit, toggle off = 1 billable unit), which is consistent with the original character definition used to define a 65-character line; or each formatted character as 2 characters, which is not. Measurable? Again, just as measurable as the VBC. Consistent? Certainly as consistent as the VBC. Again, who is going to “eyeball” for purposes of verification? Is there integrity in this method? Absolutely, as long as the parameters are transparent to the client.
The lack of integrity has been, as stated by the TF in this paper: “Many transcription service suppliers have adopted unique line-counting or character-counting definitions in order to differentiate them [sic] and stand out in a crowded field.” The lack of integrity isn’t in the definition of a billable unit! It’s in the method used to count and report billable units, the lack of resources facilities have to verify the billing as accurate and the lack of education at the facility level that results in a contract without clear language. Price shoppers get what they pay for; anyone who purchases services based on the lowest price per unit gets what they pay for, regardless of how they define a unit. And anyone who doesn’t educate themselves about billable units deserves what they get. I don’t think anyone deserves to be cheated, but anyone who buys a pig in a poke has only to look in a mirror to find the responsible party if the contents of the poke aren't inspected prior to purchase. The VBC isn't going to change the lack of integrity unless the buyers educate themselves and take steps to verify that they're being billed in concordance with the contract. I simply don't picture the same people who can't be bothered to run line count software on a document actually taking the same document and "eyeball" verifying the count!
I have no objection to standardization, but I will object quite vocally to the pretense that a subjective presentation is authoritative or objective. The fact that the Task Force chose to present such a subjective and skewed paper to the industry speaks volumes about how little commitment there actually is to this issue.





