Illinois Hospital Association

Members Login Automatically
login
  User ID:   Password: Forgot your password?
Don't have a password?

February 20, 2008

Negligent Credentialing Liability

TO: Chief Executive Officers, Member Institutions
  Please forward to Hospital Medical Directors, Legal Counsel & Risk Managers


Introduction
Last September, the Illinois Appellate Court for the First District became the first court in Illinois to uphold a negligent credentialing claim against a hospital. Frigo v. Silver Cross Hospital and Medical Center, 377 Ill.App.3d 43, 876 N.E.2d 697 (1st Dist. 2007). Three weeks ago, the Illinois Supreme Court declined to review the case making Frigo the "law of the land" for hospitals accused of negligently credentialing a physician in Illinois. This memo discusses the ruling and its implications.

To view the opinion, click here.

The Ruling
In Frigo, the plaintiff alleged that the hospital negligently renewed the surgical privileges of a podiatrist who then injured the plaintiff. After hearing conflicting expert testimony over whether the surgical privileges were proper, the jury returned a verdict for the plaintiff awarding approximately $7.8 million in damages.

In upholding the jury verdict, the appellate court held the following:

  • The Medical Studies Act does not shield hospitals from negligent credentialing claims even though credentialing deliberations and information are inadmissible in medical liability claims.
  • The plaintiff’s negligent credentialing claim did not have to meet the willful and wanton standard of proof required under the Hospital Licensing Act for hospital quality assurance actions because that standard only applied to physicians challenging adverse disciplinary, credentialing and staff membership decisions.
  • Claims for negligent credentialing are a natural extension of the doctrine of institutional negligence of hospitals under Darling v. Charleston Memorial Hospital, 33 Ill. 2d 326 (1965).
  • To establish a claim for negligent credentialing the plaintiff must prove that:
  • The hospital failed to exercise reasonable care in granting staff membership or clinical privileges to a physician;
  • The negligently privileged or credentialed physician treated the plaintiff negligently; and
  • The hospital’s negligent credentialing of the negligent physician was the proximate cause of the plaintiff’s injury.
  • Frigo is the first Illinois appellate ruling to recognize and apply the negligent credentialing cause of action in a medical liability lawsuit.

    The Implications
    Because of the confidentiality provisions of the Medical Studies Act, neither plaintiffs bringing negligent credentialing claims nor hospitals defending themselves against such claims can use peer review or credentialing committee deliberations as evidence. As in all negligence cases, the plaintiff has the initial burden of proving that the hospital’s credentialing decision was negligent and the Medical Studies Act keeps much of the evidence of the hospital’s credentialing decision out of the plaintiff’s hands. As a result, future negligent credentialing claims are likely to be based on two scenarios where the evidence of credentialing negligence falls outside of the Medical Studies Act:

    1. Failure to Follow Procedures. Similar to cases where a medical staff disciplinary decision may be reviewed and reversed because of procedural irregularities, a hospital must follow its credentialing bylaws, rules and procedures to avoid negligent credentialing claims. Courts and juries are much more comfortable holding hospitals accountable for procedural mistakes than for substantive ones which are harder to gauge. For example, proof that the hospital failed to check the physician medical liability and disciplinary data in the National Practitioner Databank would be more difficult to defend against than arguing about whether the data in the Databank supported the denial of certain privileges.
    2. Strong Suggestion of Incompetence. Sometimes a plaintiff may have strong, non-Medical Studies Act protected evidence that the physician who treated him was unqualified. Such evidence might include repeated failures to get board certification, failure to complete a residency, history of adverse patient outcomes, medical malpractice claims history and licensing sanctions. If a hospital wishes to grant membership and clinical privileges to a physician who has some potential "smoking gun" problem in his or her background, it may be wise to develop a track record or rational outside of the Medical Studies Act deliberations that would explain why that "problem" was not a barrier to staff membership and privileges for this physician. Then the hospital would be in a better position to defend itself in a negligent credentialing case.

    These observations are merely a starting point for you and your legal counsel to consider in how you decide to manage the new negligent credentialing liability under Frigo. If you have any questions regarding the decision or this memo, please contact Ted Nodzenski at (630) 276-5472 or tnodzenski@ihastaff.org.