In the case of Houwelingen v. Milton S. Hershey Medical Center, No. 1:22-CV-01388 (M.D. Pa. Aug. 21, 2024 Wilson, J.), the court denied a Motion to Compel in the medical malpractice case.
At issue was the discoverability of a PowerPoint presentation from a grand round conference.
According to the Opinion, a grand round conference involves patient-specific presentations at a medical facility which include the retrospective review of the care those patients received. Grand round presentations are used to evaluate the quality and efficiency of the healthcare those patients received and also review how to improve such treatment.
The court ruled after, an in camera review, that the Defendant hospital’s grand rounds PowerPoint presentation was protected from discovery under Pennsylvania Peer Review Protection Act.
In so ruling, the court noted that protected peer review committees need not specifically have the words “peer review” in their title, nor must they limit themselves to solely conducting peer review functions, in order to secure the protections of the act.
The court noted that the patient discussion portions of the grand rounds presentations involved professional healthcare providers assessing and critiquing the care provided by other such professionals.
The court also noted that the fact that the participants in the meeting received continuing medical education credits did not preclude a finding that the information sought in discovery was afforded the protection of Peer Review Act.