Murtha Means More

Connecticut Court Finds Hospital Credentials Committee Review is Protected Under the Peer Review Statute

November 5, 2012

In a positive development for health care institutions, a recent Connecticut Superior Court decision held that the peer review privilege extends to the activities of a hospital credentialing committee when it makes the initial decision whether or not to extend medical staff membership to a physician applicant. The Court held that such a committee is a medical review committee under the Connecticut peer review statute.  Whittington v. Altmann, 2012 Conn. Super. LEXIS 1708 (Conn. Super. Ct. June 27, 2012).  The defendant, Stamford Hospital, invoked the shield of the “peer review privilege” to avoid disclosure of material in a professional liability action.  The plaintiff first argued that because the Hospital’s credentialing committee was identified in the bylaws as a “standing committee,” it was not a “medical review committee.”  The Court disagreed because there was nothing in the bylaws which prevented the credentialing committee from being both a “medical review committee” as well as a “standing committee.”

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