“(c) Application Of Certain Regulatory Requirements.—A physician (as defined in section 1861(r)(1) of the Social Security Act) may delegate electronic medical record documentation requirements specified in regulations promulgated by the Department of Health and Human Services to a person who is not such physician if such physician has signed and verified the documentation.”. [S.2511 – Improving Health Information Technology Act]

After $28B dollars of investment the tower of Babel is finally upon us again.

If there is one thing failure mode analysis has taught us it is that communicate and review systems don’t work unless checks and balances are built in. As a pilot I have been introduced to a system called cockpit resource management. In this approach there is a focus on interpersonal communication, leadership and decision making. The first element is the most important.  We speak slowly, deliberately, and take accountability for our actions.

Pilot, “I have the controls”

Co-Pilot, “You have the controls”

This certainly isn’t what I’m expecting to see come out of the delegation of charting to non-physicians.  Effective interpersonal communication relies on speaking the same language, understanding the same nuances, and watching the actions of the other person.

As someone who spends considerable time looking at medical records I can confidently say many mistakes will be made. The scribe will start with either a verbal or written account in natural language and attempt to fill out the EMR screens from this data. This is a complex task for the physician and how can it be less so for the scribe?

It’s a nice idea that physicians will simply check the record and sign off, but what percentage of mistakes will they catch in the middle of such a complex system? I’m sure this will be studied extensively over the next five years in the academic literature and hopefully nobody will get hurt in the meantime.

As I spoke to a colleague of mine today over at one of the largest healthcare centers in the US he commented that well formatted notes have a skeletal structure. When used correctly this allows a physician to quickly orient themselves and pass through the data with minimal cognitive effort. If we truly must have scribes then the design of the information the physician is presented to review will become crucial.

Ok. Enough said. I’m off to start a transcription company before anybody else gets the idea …

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