Sham Peer Review

Survive sham peer review and protect your license

Peer review is the process by which physicians assess the work of other physicians. While being reviewed by fellow doctors can be beneficial, you may find yourself the subject of a sham peer review—a situation in which the peer review process is abused for reasons unrelated to the quality and safety of the care you provide.

Clinical peer review can have wide-ranging effects on a doctor’s career at their institution, through the National Practitioner Data Bank (NPDB), and (increasingly) in malpractice actions. Doctors, working with legal counsel, should therefore ensure that they get their full due process rights. Below, we provide a detailed primer on the peer review process, followed by a discussion of how to protect your license and survive a sham peer review.

I. The Basics of Peer Review

Doctors are often angered by the knowledge that they are judged in a medical malpractice case by a jury of laypersons, not by “their peers.” These individuals are not doctors, nor do they have any substantive medical knowledge. Even in a Medical Board hearing, some lay members will participate. A peer review, though, is just that: doctors evaluating doctors.

So, it should be fairer, right?

Perhaps…or perhaps not. Doctors must understand the process to avoid the traps and achieve the best outcome.

Peer review is best understood operationally as a performance evaluation, but unlike a periodic assessment, it is typically initiated by a “triggering” event.

That event doesn’t have to be negative. For example, it’s possible the doctor just wants to expand the scope of his privileges. However, more often, there is a complaint (or complication). This situation is the one that concerns doctors the most. Let’s dig in.

Medical malpractice actions are designed to compensate a medically harmed individual. In contrast, peer review is conducted to ensure general patient and staff safety and quality of care. The idealized version of peer review is grounded on a reasonable difference of opinion on standards of care that can be resolved inter-professionally.

But the more sobering reality is the subject doctor is being evaluated as to whether they represent a threat to their patients or co-workers.

A peer review may begin with a summary restriction of privileges or employment while the investigation proceeds. In most cases, though, the process will continue while the doctor continues to practice normally.

Peer review is conducted by a committee established solely for this purpose or even an external committee contracted by the facility or group. The second option is more common with smaller groups that lack the staff to support a separate committee or when the group wants to maintain a neutral distance from the process, eliminating a perceived conflict of interest.

The nature of the triggering event may also determine who does the review. A credentialing committee would handle a review for advancing privileges, an ethics or professionalism committee would handle a conduct issue, and a clinical committee would handle a matter of medical standards.

Any committee member with a real or perceived conflict of interest with the doctor in the crosshairs should recuse themselves. A failure to take this reasonable step opens the hospital or group to a lawsuit for conducting a sham review, and, as we will see in Part 2, this is one of the few issues that a court will consider.

Generally, yes. But not always. Regardless, there needs to be a contemporaneous record of some type of investigation; meaning a hospital cannot retroactively argue that the doctor was under investigation and because the matter was serious, no notice was given (unless its internal records truly reflect that). If and when a doctor’s privileges are curtailed, they will be informed. Obviously.

A doctor notified that a peer review process has started must contact his insurer immediately. This will satisfy any notification requirements and will get the doctor assigned to counsel.

If they are not covered for this (every doctor should check their policy to make sure they have coverage and that coverage is adequate!) then the doctor should hire independent counsel experienced in disciplinary actions as soon as possible. The most significant error that a doctor can make is to assume because this is a process run by other doctors, they can just “explain themselves” and put an end to it. And that will be that.

Peer review may not be conducted in a court, but it has legal underpinnings that are foreign to most doctors. The process can have dire consequences. And so one is well advised not to just wing it.

Then comes the step that many doctors will find difficult: Stop talking.

Following this advice will be challenging. Unlike the defendant in a malpractice case – conducted in deposition rooms and courtrooms – or as the subject of a Medical Board hearing at the Board’s offices, a doctor under peer review will feel that they are on familiar turf.

They will lower their restraint. They will likely see their accuser and evaluators in the hallway or the cafeteria. However, friends and colleagues receiving the doctor’s vents may become witnesses.

Trying to talk to staff about the situation may be misinterpreted as intimidation. Any attempt to discuss the matter with a committee member will be viewed as trying to obstruct the process. Silence except as to counsel – where the communication is privileged – is unequivocally the safest route.

And any conversation with counsel should never use any hospital/group device or any hospital/group email account. Because doing so can be held to have waived that privilege.

To be safe, set up a dedicated email account (or use your personal email account) for the case and use a temporary phone (or a phone not connected to the hospital in any way).

The best first step is to do an honest review, objectively considering the records and the facts the committee is investigating.

If the allegation concerns the quality of care, the subject doctor should compile citations from texts and journals to support what they did and why. If the issue is a matter of conduct, they should be prepared to explain the behavior in context.

Then review those facts with the lawyer. This is protected communication. So this must be an honest discussion. Don’t hold back. If the lawyer can craft a soft landing, then this is the point to start that effort.

The practical steps derive from ethical requirements the peer review committee should follow. For the review to be fair and objective, the alleged wrongdoing must be specified. And the committee must investigate all relevant facts. No cherry-picking. The subject doctor must receive adequate notice of the process and their right to a hearing.

The committee will gather and review documents and may conduct interviews with complainants and witnesses. The subject doctor will be allowed to see what was considered and may provide their own explanations in writing or at a hearing.

The reviewers will assign a score to their findings. This can range from “nothing to see here” to extreme severity.

For example, in a clinical practice matter, the finding may range from “no error” to “catastrophic error,” with multiple intermediate levels. The perceived severity level determines whether a subsequent action is warranted and, if yes, whether it will be corrective (such as training or monitoring) or punitive (privilege restriction or loss, referral to Medical Board or prosecutor).

The subject doctor may also request a hearing, where they can be represented by counsel, for appeal after a negative review. Still, this will occur within the peer review system, not in court. The time frame for exercising the hearing is strict. Failure to meet deadlines will be treated as having waived the option.

Peer review hearings come under the Administrative Procedure Act of 1948, but that statute only deals with generalities; for example, the review is supposed to be in a neutral forum, and the subject is entitled to counsel and confront witnesses.

Constitutional due process, which is very protective of the defense side, may or may not apply.

If the hospital is governmental, or if the review is covered by state laws that impose due process requirements, then those will apply. But in an entirely private setting, the facility’s regulations will control. What then determines a subject doctor’s rights in this critical process are their employment contract, their partnership agreement, and/or very importantly, the bylaws of the facility or group.

A more modern stature, the Health Care Quality Improvement Act (HCQIA), which we’ll discuss in more detail in Part 2, requires private entities to provide due process as the quid pro quo for conditional immunity from lawsuits over peer review activities.

However, HCQIA doesn’t enumerate specific protections, and due process can be overridden in critical circumstances without losing HCQIA protections.

Most cases, though, will not require emergency curtailing of the subject doctor’s activities or status, and most bylaws and contract terms will be facially fair. So, the primary issue will be whether the due process protections were actually applied.

In that context, the subject doctor should request a copy of the most recent version of the bylaws. That document, and any contracts or agreements with the hospital/group, should be sent to counsel.

Sometimes the subject doctor is presented with this Hobbesian choice. If they don’t agree to a partial or complete restriction of their privileges while the review proceeds, or if they do not immediately resign, the hospital will initiate peer review that will result in actions that are reportable to the state medical board and the National Practitioner Data Bank (NPDB).

A subject doctor faced with such a situation should keep two facts in mind:

  • If the bylaws permit such, the committee already has the inherent power to summarily limit or remove a doctor deemed too dangerous to patients or too disruptive to staff while the peer review process is carried out. A demand the doctor sign off on this is designed either to get a veneer of consent as protection for the hospital/group or to have the doctor agree to a condition the committee actually lacks the bylaw authority to impose on its own.
  • As we will see below, accepting a practice limitation, or resigning, to avoid a peer review will itself be reportable. Ugh.

The subject doctor should instead immediately call their malpractice carrier to receive representation and let the lawyer interface with the facility on their behalf.

As you will see below under “Recognizing When It’s Improper and How to Fight Back,” suing after the fact is challenging for the doctor. So, no doctor should just sign away their privileges or employment in the belief they will be able to claim duress later.

If the lawyer can’t work this out with the committee, it may be necessary to seek equitable relief from a court. This may seem confusing since the peer review is not a legal proceeding. 

However, peer reviews only take place because the relationships that underpin it – employment or facility bylaws, contracts, partnership agreements, etc. – are legally enforceable and a court can adjudicate claims that arise from them.

The subject doctor can seek a declaratory judgment to state their rights. If their privileges are neutered, they can seek an injunction compelling reinstatement while the review process plays out. Such action is not futile.

Only those entities with formal peer review, which includes due process and appeal rights, whether in-house or by a free-standing committee, may report the results of a peer review to the National Practitioner Data Bank (NPDB).

Adverse actions by a peer review committee that affect the doctor’s privileges and/or ability to practice for more than 30 days are reportable to the NPDB. These include individual restrictions on performing specific procedures or a requirement for monitoring, suspension of privileges, and revocation of privileges. If one cannot independently exercise privileges, that’s a restriction. If restricted for more than 30 days, that’s reportable to the NPDB.

Voluntary submission to a restriction or loss of privileges is also reportable if done while the doctor is under investigation by the peer review committee or to avoid an investigation.

Although the doctor should receive notice that the review exists, dates can overlap. So if there is any ambiguity and the doctor wants to leave, they should first get a written statement from the facility that there is no investigation going on or planned at that time. Read this sentence again. The toothpaste can’t be put back in the tube.

However, a report to the NPDB by the entity after an adverse action cannot be submitted before a final determination, which includes hearings and appeals. Pre-emptive reporting by a facility before a matter is fully adjudicated is a serious violation. If the case goes against the subject doctor but is not yet closed, they should request copies of their file from the NPDB, keeping tabs on the date of any report, and should inform the NPDB of any premature reporting.

The NPDB’s dispute resolution process doesn’t look at the underlying reasons for the report, such as the merit of a complaint, or whether the reporting entity treated the subject doctor fairly. It only considers whether the report conforms to its regulations, such as timing, as just discussed.

If a report is upheld and the doctor still believes it does not reflect essential context and facts, they should supplement the report with a personal statement drafted with their lawyer. The NPDB will publish this in its database and send this update to any recipients who previously received the report.

Peer reviews have traditionally been kept confidential. However, the opinion of a peer review committee, perceived by jurors to be acting for public health, will likely carry more weight than a hired expert, and will not be subject to cross-examination.

Courts have become more willing to order the release of information that may bear liability in a malpractice action. This is because they do not fear a chilling effect on the process itself. After all, peer review will still be mandated by applicable law and by regulatory and professional organizations.

A plaintiff seeking the release of a negative review will argue that HCQIA and state immunity will protect the reviewers themselves but that the results of the review should be available, as a matter of public policy, to a medically-harmed individual seeking compensation.

A defendant doctor seeking the release of a positive review would either have to get the committee to waive confidentiality or move to have it released. Of course, they can waive their own confidentiality and testify about the results of their own review.

Below, we will look at situations where the peer review system is abused.

Jeffrey Segal, MD, JD
Chief Executive Officer & Founder

Jeffrey Segal, MD, JD is a board-certified neurosurgeon and lawyer. In the process of conceiving, funding, developing, and growing Medical Justice, Dr. Segal has established himself as one of the country’s leading authorities on medical malpractice issues, counterclaims, and internet-based assaults on reputation.

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II. Recognizing When Peer Review is Improper, and How to Fight Back

The general rule is that peer review is an immunized process under federal and state law. A subject doctor should never assume that they will be able to bring a lawsuit later. Instead, they and their lawyer should challenge every improper step along the way to either correct the process or create a record that will persuade a later court to pierce the immunity shield.

As we explained above, the peer review process has the benefit of doctors being the evaluators. However, it can be done incorrectly or misused either as a personal grievance or a business gambit, all while enjoying a presumption of being proper. Doctors, therefore, need to be aware of how to safeguard their interests.

Are peer reviewers immune for their actions?

When peer review became common in the 1980s, subject doctors often responded by filing lawsuits against facilities and reviewers. A ruling by the Supreme Court (Patrick v. Burget) allowed a doctor who lost his privileges to prevail against competitors abusing the peer review process. The legal theory was state anti-trust law. At the time, the outcome predicted a chilling effect on the willingness of doctors to serve on peer review committees.

The Health Care Quality Improvement Act (HCQIA) addressed this concern by establishing qualified immunity for peer reviewers.

Under this statute, a reviewer or entity could get a legal case against them dismissed if they could show:

  • Good faith, meaning that the review was undertaken in a reasonable belief that it was to further health care quality, and only after a reasonable effort to actually obtain the facts, and that those facts warranted a review.
  • The procedures were fair to the subject doctor.

HCQIA presumes a process to be fair if five elements are met:

  • Notice
  • A hearing with a record or transcript
  • The right to an attorney
  • The right to call and cross-examine witnesses
  • The right to submit written argument after the hearing

States have also created such “safe harbors” in their own laws.

As a matter of public policy, peer reviewers are provided significant protections.

This also applies to cases with summary limitations or removal of privileges during the review. In that regard, courts look to the principle of patient protection that underpins the peer review process.

A reviewer can therefore expect to win on an immunity defense if:

  1. their actions were part of a standardized professional review (even if it is not specifically called “peer review”),
  2. the facts at the time made that review objectively reasonable (even if later proven wrong), and
  3. the subject doctor received due process within the parameters of patient safety.

Can the doctor sue if the peer review is just a sham?…

The doctor can bring their case only if they can defeat the immunity shield.

In this setting “sham” has a precise meaning. It doesn’t mean that the subject doctor disagrees with the review or that the review turned out to be unfounded after all the evidence was presented – it means that the review was unfair, that it targeted the doctor without merit, likely prompted by personal or business reasons.

…which should be provable, right?

Well, only if the doctor can even bring their case.

How the Courts Have Interpreted HCQIA

Courts start from the doctrine of non-review in evaluating the substance of these investigations. The peer review process is firmly institutionalized under federal (HCQIA) and state law as a necessary safeguard of public health and is afforded great presumptive credence.

The “business judgment rule” also factors as relevant. That rule holds that the governing board of a private entity has the right to determine and direct its internal business affairs. In the case of a hospital, those business affairs include defining medical standards. So, courts will err on the side of the self-policing that the peer review process allows.

Courts also tend to view hospitals as virtuous entities solely focused on safety and quality. They will start with the assumption that the goal of any investigation is to uncover and prevent problems in care.

The result is that HCQIA has been interpreted to permit immunity for a hospital’s peer review regardless of “animosity,” “hostility,” or “bad faith.”

Mixed-Motive Peer Review Processes

Even a mixed motive will not defeat a court upholding immunity for the review. The prototypical example of a mixed motive case was Poliner, where the doctor’s care was considered questionable, but there was also a well-argued business competition overlay.

Cases Where Peer Review Process Has Been Considered Improper

Courts found the peer review process to be sufficiently improper when it involved other important public health policies. For example, when a doctor was sham reviewed for revealing the hospital’s breaches of EMTALA. Or the case where only two charts were eyeballed before the doctor’s privileges were revoked and a false report was sent to NPDB for review. This was considered well outside HCQIA’s good faith requirements. There, immunity for peer reviewers was lost.

Challenge Any Corruption of the Process in Real Time—Not Later

Still, a doctor should not sit idly by pinning one’s hopes on a lawsuit down the road. Instead, they should challenge any corruption of the process while it is occurring.

However, not all poorly conducted peer reviews are shams. Some are just procedurally sloppy, with poor record keeping and a lack of formality, and others are based on mistakes, with reviewers acting outside their authority. However, even if there is an intention to be fair to the subject doctor, those lapses in process can also deny them their due process rights in a practical sense.

Each step in the process should be independently reviewed by the subject doctor and their lawyer to determine if it should be challenged.

The nature of the reviewing body itself is a threshold issue. Remember that only a formalized review with due process and an appeal option qualifies for immunity. The reason for this is obvious: a hospital or group should not be able to convene a kangaroo court to go after the doctor. However, that a committee is a standing entity does not make it appropriate if its procedures lack the required protections. A stand-alone committee set up just for the particular complaint and not even titled as “peer review” may still pass muster if it meets the due process and appeal criteria.

How can the subject doctor push back on an improper peer review process?

The next step for the subject doctor is to assert the entitled due process at every step.

Notice is a critical issue. Substantively, the doctor is entitled to know if a review has started and what the allegations are. Importantly, while the bylaws may mandate that doctors be informed (provided notice) of a pending investigation, the Data Bank requires no such condition. However, the procedural aspect matters as well. Notice must be given by the timing and specific method (for example, in writing by certified mail) that the bylaws require. If the notice is procedurally defective, it should be challenged even though the defect will likely just be corrected – the challenge puts the committee on, well, notice, that the subject doctor is aware of their rights and is paying attention.

Notice also goes back to the right to correct a problem under a contract, privileges agreement, partnership agreement, or the bylaws. Any issue about a doctor’s professional or personal conduct sufficient to warrant a peer review was likely identified earlier. Suppose their association document or bylaws include a right to be notified of a problem contemporaneously and to allow such a problem to be remedied within a specified time. In that case, bringing an onerous summary proceeding instead is a breach at best and a marker of essential bad faith at worst.

The reviewers are then responsible for keeping a record of copies of every document that was reviewed. The failure to do so suggests that the review is not being conducted with the required formality. It also suggests a lack of a basis for the review. In other words, if it is just a sham, then formal foundational documentation will be missing. This can serve as another real-time challenge.

Ask for the Records in Writing

Complaints, Incident Reports, or Formal Requests for Intervention

If the subject doctor is not furnished with all complaints, including incident reports and any formal requests for intervention, they should demand those in writing. The failure to supply them also goes to a lack of due process or possible evidence of a sham proceeding.

Such statements should then be reviewed for their actual substance. The doctor and their lawyer should be looking for (a) anonymous reporters, (b) uncredited hearsay (“Lots of nurses have told me that Dr. A is very rushed when he closes episiotomies”), and (c) allegations by competitors or solely by administrators on medical matters without medical staff back-up. All such statements should be challenged in writing.

Committee Proceeding Records

A legitimate peer review committee will also maintain appropriate records of its proceedings. A qualified individual, such as a medical staff secretary, should be taking the notes and transcribing them into formal minutes the committee approves. In particular, which committee member reviewed what document or what aspect of the case should be noted. Records should also include specific comments and concerns and any responsive discussion by the other committee members. Failure to do so and just making conclusory notes or keeping vague minutes undermines due process—and may support a thesis that the process is about something other than actual correction of a specific care or conduct problem. 

(Again, challenges should be submitted in writing.)

Actual pre-judging of the matter would, of course, make any subsequent procedure a sham by definition. However, such language will not likely be stated in the minutes. Nevertheless, the subject doctor and their attorney should also be on the lookout for evidence that rubberstamping of a pre-ordained conclusion is what really happened.

Pay attention to the presence on the committee of professional rivals or anyone with a personal grudge. A committee hand-picked by the hospital CEO is also suspect. The subject doctor can demand appropriate recusals. The Patrick case focused on peer review as a cudgel against a competitor. Courts will take this issue very seriously. So, the subject doctor wants to get their objection into the record, even if the request for recusal of the conflicted member is refused.

If there is a hearing, a transcript should follow. If the hospital committee refuses, then the subject doctor should offer to pay for a court reporter. And file a written objection if that offer is refused. Any of the following actions should be noted in that record, such as (a) withholding needed charts, (b) not permitting cross-examination of witnesses, (c) not permitting the subject doctor’s expert to testify, (d) withholding exculpatory evidence, (e) witness intimidation, and (f) inappropriate behavior by committee members during the hearing. (In a state that allows it, surreptitious taping should only be done with the lawyer’s knowledge and permission.)

The committee’s final action may demonstrate that the process was a sham if it is arbitrary or punitive without a nexus to the allegations. For example, requiring psychiatric clearance for a subject doctor whose mental state was not an issue. If the committee’s power is exceeded, this can serve as evidence of a fundamental error in the process or an intentional sham. For example, a committee concluding the subject doctor’s privileges are revoked when the peer reviewers can only recommend such action to the Medical Executive Committee.

Look Out for Unethical Commentary Outside the Official Proceedings

The subject doctor should also keep their ears open for anything outside the room where the committee meets. As discussed above, the subject doctor should not discuss the process. The same goes for the committee members. While ongoing, the peer review process is supposed to be kept confidential. Comments in the doctor’s lounge or at a party may also provide evidence the process was always a sham. Finally, talking outside the process can strip a reviewer of their status as an agent of the hospital or group. As an “individual” without immunity, the reviewer may be vulnerable to an allegation of conspiring with other doctors or with the facility to “get” the subject doctor.

These points may not stop the improper process. But successful legal challenges have been based on stripping immunity related to procedural defects and denials of the entitled due process. Challenging the process will ideally correct the problem. Regardless, it critically preserves the facts that suggest impropriety for a later lawsuit.

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