TRENDWATCH PIC
WISCONSIN January 2006 • Volume 11, Issue 1
PEER
REVIEW: PRIVILEGE AND PROCESS
PEER
REVIEW ESSENTIALS
DEFENDING
THE PRACTICE OF MEDICINE: 20 YEARS STRONG AND GROWING
STRONGER
ADDITIONAL
INFORMATION ABOUT THE MERGER AND WHERE TO FIND IT
|
MESSAGE
FROM THE PRESIDENT
As
we begin 2006—PIC WISCONSIN’s 20th year—I am very pleased to announce the
company’s proposed merger with ProAssurance, the nation’s fourth largest
professional liability insurer. We believe the proposed merger,
which is
still subject to shareholder and regulatory approval, is in the
best
interest of all our constituents—shareholders, policyholders, and staff
alike. PIC WISCONSIN is in superb shape: fi nancially strong, with
industry-leading claims results, client-recognized risk management
and
customer service, and tireless advocacy for physicians. As always,
we
continue to improve the service and protection for our insureds
for the
long run. For more than ten years, PIC WISCONSIN’s board sought a
long-term solution for providing value to our shareholders. In
the end,
the best solution was to fi nd a partner whose principles closely
matched
ours. Physician founded, focused, and led, ProAssurance’s values are
highly compatible with PIC WISCONSIN’s core principles. They emphasize
risk management, fi nancial strength, and the best claims defense
possible. ProAssurance acquisitions retain their own identity and
continue
to manage their local underwriting, risk management, and claims
functions,
so PIC WISCONSIN will continue to serve you with the added advantage
of a
stronger fi nancial and operational foundation. See “Defending the
Practice of Medicine: 20 Years Strong and Growing Stronger” for more
information about our potential merger. In regional news, the medical
malpractice climate in Wisconsin was dealt a blow once again by
the
Wisconsin Supreme Court, who, in a recent decision, allowed a 14-year-old
disabled child to sue for malpractice, thereby negating the previous
statute of limitations for minors of three years from date of injury
or
ten years of age, whichever is longer. While this was a very narrow
decision that may be legislatively correctible, it points to the
gradual
erosion of our legal environment
since
the change in composition of the Court took place in early 2005.
PIC
WISCONSIN continues to advocate for meaningful tort reform, including
caps
and reasonable statutes of limitations, and encourages our Wisconsin
insureds to add their support. Visit the Wisconsin Medical Society’s
campaign at www.keepdoctorsinwisconsin.org for updates and ideas
on how
you can help restore our home state’s medical malpractice
climate.
I
also invite you to take a close look at “Peer Review: Privilege and
Process” in this issue of TrendWatch. It features best practices
that will help you protect your peer review information from discovery
by
a plaintiff’s attorney and protect your reviewers from lawsuits. As
always, we strive to bring you risk management strategies that
you can
adapt to your situation or use as a starting point for further
discussion
with your risk management consultant. Thank you, as always, for
choosing
PIC WISCONSIN. Your comments, ideas, and questions are always welcome.
Best wishes for a happy, healthy, and prosperous 2006.
William
T. Montei
President
and CEO
|
PEER
REVIEW: PRIVILEGE AND PROCESS
How
do you ensure a careful, fair peer review? What must you do to protect
peer review information from discovery during a lawsuit?
How
do you preserve immunity from damages for your reviewers? The stakes
are
high for all concerned.
Credentialing
and peer review may help hospitals and medical groups avoid substantial
risks not only from malpractice claims, but also from internal
disruptions, antitrust actions, and staff who leave when problems
are not
addressed. Perhaps most importantly, these continuous quality improvement
processes help you uphold proper standards of patient care. Although
the
legal environment varies from state to state, there are a number
of steps
you can take to ensure your credentialing and peer review processes
can
effectively address the needs of your organization. Before taking
any
action, however, consult an attorney who is knowledgeable about
health
care law.
WHERE
TO BEGIN: MEDICAL STAFF BYLAWS
Medicare
Conditions of Participation (COP) (42 CFR §482.22) spell out the basic
requirements for the organization of the medical staff, the staff’s
accountability to the governing board for the quality of patient
care, and
the requirements for the medical staff bylaws. While these
regulations
are
hospital oriented, medical groups may model their internal rules
after
them. It is important to map out the entire credentialing and peer
review
process
in your organization’s bylaws so reviews can be consistent
and
closely
tied to quality improvement throughout. Here are the
essentials
that
must be included: • Describe the qualifi cations of each candidate so the
medical staff can recommend appointment to the governing board.
This
description will vary by specialty and department. Medical staff
departments may be designated to address both these qualifi cations
and
the
candidate’s privileges for specifi c procedures. Job
descriptions
for
employed physicians should also include these requirements.
•
Identify the information that must be available for review by
the
medical
staff. This typically includes primary source verifi cation
of
education and training, past experience, and disciplinary and malpractice
history. Proof of malpractice insurance coverage at the
minimum
limits set by the board is also recommended. • Describe how and why a
review is initiated. A review can be initiated as part of the
credentialing or recredentialing process or whenever reliable information
suggests that performance or behavior is detrimental to patient
safety, or
is unethical or unprofessional. • Determine who conducts the
investigation. Medical staff department or medical executive committee
(MEC) designees form the peer review committee. Include criteria
for
external
review.
• Establish confi dentiality and immunity requirements. Limit information
gathering, documentation, and information sharing outside of the
investigating committee. Bylaws should emphasize the confi dentiality
of
any documents produced by the committee. Refer to state statutes
so your
process refl ects the immunities provided. • Describe the range of defi
ciencies and their remedies. Peer review covers every aspect of
clinical
treatment and behavior from minor defi ciencies to criminal behavior.
The
following are among the defi ciencies you will need to address:
• Minor
defi ciencies are addressed and monitored through additional training
and
supervision. • Physical and mental impairment issues are referred to the
physician health committee. Your bylaws should also address remedies,
such
as the following:
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•
Summary suspension addresses an immediate threat to patient
safety.
•
Restriction and revocation of privileges may be recommended by
the
investigating
committee for serious defi ciencies. The MEC has the authority to
act. •
Establish a fair hearing process. Adverse decisions may require an
external or second review to ensure basic fairness. • Defi ne compliance.
Make sure bylaws and policies also include a defi nition of
an
“abuse-free workplace” and spell out the types of behavior that the
organization will not tolerate. This should include regulatory compliance,
i.e., billing and documentation requirements and behaviorial
expectations.
•
Address monitoring. Evaluate the peer review process and outcomes
for
effectiveness in improving patient safety through credentialing and
process improvement. Conduct periodic legal reviews of the process
for
compliance with changing regulations. Physicians must go through
the
credentialing process at least every two years, including a National
Practitioner Data Bank (NPDB) query and a performance review by
the
department
or committee chair as part of the evaluation of the physician’s
competence. PEER REVIEW Peer review is a process in which a clinician’s
treatment of patients is evaluated by his or her equals in experience
and
training. It is a continuous process that is critically
important
to patient safety and is often challenging to administer. A sensitive
issue to begin with, peer review can be complicated by
changing
legal interpretations and the politically-sensitive situations that
develop when referring physicians or partners are subjected to increased
peer scrutiny. Physicians participating in peer review and their
organizations can avoid litigation, specifi cally antitrust or
discrimination claims, arising out of their peer review activities
by
adhering to a process that is consistent and fair to all who apply
for or
renew membership
to
the medical staff. The “fair hearing” requirements are outlined in the
Health Care Quality Improvement Act (HCQIA) of 1986 and should be
incorporated into the medical staff bylaws and more importantly into
the
actual
activities of the peer review committee. Peer review regulations
have been
evolving since federal mandates were established to improve health
care
for Medicare benefi ciaries in 1982. HCQIA and state statutes resulted
in
standards for peer review actions and protection from liability for
reviewers. In 1989, subsequent HCQIA regulations created the NPDB,
which
made it diffi cult for physicians who had been disciplined to relocate
without their malpractice and disciplinary histories being available
for
review. The Data Bank requires that adverse peer review actions and
malpractice claims payments be reported and that hospitals, licensing
boards, and other entities consult the Data Bank before granting
or
renewing a physician’s or dentist’s license or privilege to
practice.
PATIENT
SAFETY & QUALITY FOCUS Ideally, peer review tends to be more
preventive than punitive. According to Mary Becker, vice president,
Kenosha Hospital & Medical Center (WI), “Peer review provides feedback
for practitioners, helping them address clinical, professional, and
personal problems before the need for corrective action arises.” She
describes an effective peer review process as having the following
characteristics: • Consistently follows a defi ned procedure
•
Adheres to time frames • Evaluates facts based on defensible
standards
of
practice • Considers the reviewee’s opinions to ensure
balance
•
Results in useful outcomes, including privileging and process improvement
TRIGGERS One of the hallmarks of a fair process is that all providers
are
reviewed based on the same standards. For example, using preestablished
criteria to determine which charts are reviewed can help demonstrate
that
the process itself is fair and consistent for all members of the
medical
staff. “Organizations should determine which indicators may warrant a
peer review,” says M. Jeanne Bock, RN, physician peer review
coordinator,
Institute for Quality Healthcare, Iowa City (IA). JCAHO Medical Staff
Standards and COP require performance improvement activities related
to
the diagnosis and treatment of patients, but leave it
to
the institutions to determine how they will identify subjects for
possible
reviews. Bock lists the following events for consideration: • Unexpected
death during hospitalization • High complication or death rate within
a
specifi
c procedure code
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•
Unscheduled returns to ICU within 48 hours of ICU discharge
•
Unplanned admissions following an outpatient surgical
procedure
•
Readmission within 31 days for the same or related condition
•
Hemoglobin less than 8 with no blood transfusion
•
Unplanned return to the OR for the same condition during the same
hospitalization or a correction to previous surgery
•
Neonates with an Apgar of 3 or less at 5 minutes and a birth weight
of 3.5
pounds or greater
•
Infants weighing less than 4 pounds
•
Injury to a fetus
•
Maternal death within 42 days postpartum
MANY
OPTIONS
A
peer review committee’s recommendations must be consistent with the nature
of the problem it discovers. For example, clinical competence may
be an
issue in a very small subset of a physician’s procedures that
can
be
remedied through additional training and supervision in that area.
Or, a
physician may be performing the procedure in question so rarely that
he or
she cannot maintain the basic skills needed for consistently
highquality
results.
In other instances, a physician’s physical or mental impairment may be a
threat to patient safety and the committee’s recommendations will include
a referral to the physician health committee. The medical
staff
bylaws should allow for a broad range of remedies for identifi ed
issues.
Draconian actions such as summary suspension for minor problems are
not
effective and are likely to result in litigation. Failure to institute
adequate requirements and suffi cient follow up may not change the
poor
results and may subject the hospital to negligent
credentialing
and
monitoring of performance claims.
CONFIDENTIALITY
CONCERNS
It
is important to defi ne exactly when the peer review process begins
so
immunity and confi dentiality can protect your investigation from
the very
start. According to Laurette Salzman, PIC WISCONSIN risk management
consultant, “An attorney should review your peer review policies
periodically to help you comply with your state’s confi dentiality laws.”
Some courts have ruled that information used to begin a peer review
was
not part of the review itself and is discoverable. To avoid
this
scenario,
the peer review committee should formally initiate an investigation.
This
is often done by giving the committee chair or the
medical
director the authority to initiate and conduct investigations on
behalf of
the committee. This allows for more timely responses when issues
are
identifi ed and provides the committee with the initial investigative
materials to start its review.
Plaintiff’s
attorneys typically argue that the plaintiff’s and the public’s interests
in proving and punishing malpractice overrides the organization’s confi
dentiality privilege.1 In some instances, state laws are pushed
aside
in
favor of federal laws which do not protect peer review materials
from
discovery. Mike Rausch, PIC WISCONSIN risk management consultant,
adds,
“Courts tend to view the confi dentiality of peer review information
narrowly. That’s why it is important to manage the process so
carefully.”
Attorney
Lori Gendelman of Otjen, Van Ert, Lieb, & Weir S.C. in Milwaukee (WI)
notes that Wisconsin puts the burden of proof on the peer review
organization to demonstrate that its information is privileged and
cannot
be released to a plaintiff’s attorney. For example, a hospital
administrator’s interview of a hospital employee about the
plaintiff’s
emergency
C-section was released because the administrator was acting on behalf
of
the hospital, not the hospital’s peer review committee (Mallon v
Campbell). “Although some states have stronger peer review confi
-
dentiality
laws than Wisconsin does, recent interpretations in Texas, Georgia,
and
Florida suggest there may be a trend toward less
protection
overall.1 Gendelman offers the following recommendations for maintaining
confi dentiality in an increasingly pro-disclosure
environment:
•
Describe the peer review process and its purpose, and emphasize the
confi
dentiality of the process and any documents arising from the review
in
your bylaws. • Make sure that peer review investigations are carried out
solely by members of the committee.
•
Document an investigation as beginning at the initiative of the peer
review committee. Although someone may contact a member of the committee
with a concern, the process does not begin until the
committee
issues
a formal statement that it is beginning an investigation as part
of
a
program organized and operated to improve the quality of patient
health
care at the organization.
•
Avoid ad hoc reviews. A formal, fully compliant process is the best
protection.
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DEFENDING
THE PRACTICE OF MEDICINE: 20 YEARS STRONG AND GROWING STRONGER “The
successful company you see today is the result of physicians helping
physicians,” says Andrew Ravencroft, vice president – operations at PIC
WISCONSIN. “Twenty years ago, Wisconsin physicians banded together to
provide each other with
affordable
and stable medical malpractice insurance. As a result of their vision
and
investment, PIC WISCONSIN has grown to become a leading regional
insurer
in the eight states we serve. Above all, we are known for our unsurpassed
defense of non-meritorious claims, risk management
consulting,
fi nancial stability, and customer service.” Adds Bill Montei, president,
“Everything PIC WISCONSIN has achieved comes out of the strength and
skill
of its people—staff and shareholders—and the support of our customers who
believe in PIC WISCONSIN’s core purpose. Together, we defend the practice
of medicine.” Dr. Ayaz Samadani, a long-time shareholder and customer, and
a current board member, credits PIC WISCONSIN as a stabilizing force
for
Wisconsin’s malpractice climate.
“When
I began practicing in the 70s, medical malpractice insurance was
diffi
cult to obtain affordably, making it diffi cult to open and sustain
a
profi table practice.” PIC WISCONSIN helped make Wisconsin a
physician-friendly state with affordable coverage and outstanding
defense
of nonmeritorious claims. Patients have benefi ted from the infl
ux of
physicians in response to affordable, available insurance, the
state’s
prior
limits on non-economic damages, and its Injured Patients and Families
Compensation Fund. “As conditions worsened elsewhere,
the
number of physicians doubled here. The people of Wisconsin have an
excellent health care network, as do many of the other states we
serve,”
he adds. PIC WISCONSIN continues to adapt and improve its service.
In
December of 2005, the company announced that it signed a defi
nitive
agreement
calling for a merger with ProAssurance Corporation. This will help
both
companies better serve their policyholders while also meeting the
shareholders’ needs. WHY CHANGE NOW? “The main driver,” says Dr. William
Listwan, current board chair and board member since
the
company’s inception, “is the need to provide shareholders with liquidity
options. When PIC WISCONSIN was founded, all of our insureds were
shareholders. Now we have many more policyholders than
shareholders
since we have added new states and many of our shareholders have
sold or
merged their practices. Although the majority of our shareholders
continue to be individual physicians, the majority of
shares
are owned by institutions and groups. Both are looking for a
fi
nancial return on those shares. The board has explored many options
and
unanimously supports the proposed merger. It is the right choice
for our
shareholders, insureds, employees, and ultimately, the medical malpractice
insurance climates of the states we serve.” Although Dr. Samadani donated
his shares to the Wisconsin Medical Society, he agrees
with
Dr. Listwan’s assessment. “When we began PIC WISCONSIN, everyone put their
money in with no expectation of return. It was something we needed
to do
to make Wisconsin a better place to practice medicine. As the composition
of our shareholders changed over time, with many of them holding
large
quantities of stock, it is reasonable that they expect a fi nancial
return.” Industry trends are also driving the change.
Medical
malpractice insurance carriers are consolidating. “PIC WISCONSIN’s
successful growth through entry into new markets is an increasingly
rare
phenomenon,” states Ravenscroft. “Most insurers that expand The
Wisconsin Medical Society and insurance experts from a physician-owned
insurer in Ohio founded PIC WISCONSIN in response to the medical
malpractice insurance crisis of the mid-1980s. Since then, PIC WISCONSIN
has helped Wisconsin achieve a stable medical malpractice
insurance market that has only recently become threatened. New challenges,
new opportunities, and a new player suggest an even stronger
company and better outcomes for the decades ahead.
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into
new states fail, unless that entry is the result of a successful
merger or
acquisition with a company already doing business in the state.” With the
rise of fewer, larger, more powerful carriers, PIC WISCONSIN
is
unlikely
to continue to grow by judiciously adding new markets. ProAssurance
and
its predecessor companies have a track record
of
successfully merging with physiciangoverned companies and serving
its
customers in ways that are highly compatible with PIC WISCONSIN’s history
and strengths, as shown by the following list of shared
strengths:
•
Founded to combat the medical malpractice crises of the 70s
and
80s
•
Rated “A-” by A.M. Best
•
Physician governed
•
Actuarially responsible pricing
•
Local claims and underwriting expertise
•
Leaders in aggressive defense of nonmeritorious claims
A
MATCH MADE IN OHIO
“I
am very comfortable with ProAssurance,” says Montei. “I’ve known its
president, Vic Adamo, for more than twenty years and have seen what
he and
Dr. Crowe, the CEO and board chair, have accomplished. Both
ProNational,
one of the predecessor companies to ProAssurance, and PIC WISCONSIN
were
formed with help from Physicians Insurance Company of Ohio (PICO).
PICO’s
dream of forming a “confederacy of physician- owned, physician-governed
companies” never came to fruition, but it’s interesting that four of the
original six PICO-assisted
companies
(including PICO’s book of business) will now be in the ProAssurance fold.
ProAssurance is also the industry leader in fighting claims. Adds
Ravenscroft, “That’s especially important since the Wisconsin Supreme
Court struck down non-economic damage caps. Physicians in Wisconsin
and
our other states will be best served in the long
term
if we merge with a carrier who is tough on claims defense.” Ravenscroft
believes that ProAssurance’s fi nancial strength and
economies
of scale and PIC WISCONSIN’s customer focus will result in a truly
formidable stabilizing force for the regional med mal insurance market
for
the long term. WHAT’S NEXT?
The
merger must fi rst be approved by Wisconsin’s Offi ce of the Commissioner
of Insurance (OCI). The OCI controls the process and its
timing.
If approved, the decision then passes to the shareholders who must
ratify
it by a simple majority of shares entitled to vote after the Securities
and Exchange Commission (SEC) has approved the wording of the
proxy.
The
entire process may take as much as six months or more, but is well
worth
the time. “We are pleased to be making this proposed merger from a
position of strength,” concludes Ravenscroft. “PIC WISCONSIN
is
fi
nancially sound, well-run, and unsurpassed in claims defense, risk
management, underwriting, and customer service. We are at the pinnacle
of
what we can accomplish unless we take on a like-minded partner.
If
we
were not to complete the merger, PIC WISCONSIN would remain at continued
risk of a hostile takeover; we must satisfy our shareholders’ need for
liquidity in a way that will continue to benefi t our customers and
help
create a stable market for physicians in all of the states we serve.
Our
reputation,
products, and states complement those of ProAssurance. We anticipate
a
long and stable future serving the physicians, hospitals, and dentists
of
our region.”
ADDITIONAL
INFORMATION ABOUT THE MERGER
AND
WHERE TO FIND IT
ProAssurance
Corporation will fi le a registration statement with the Securities
and
ExchangeCommission (SEC) that will include a copy of the prospectus/proxy
statement and other information regarding ProAssurance and the proposed
transaction. PIC WISCONSIN and
its
respective directors and executive offi cers may be deemed to be
participants in the solicitation of proxies from the stockholders
of PIC
WISCONSIN in connection with the proposed merger. Information about
the
directors and executive offi cers of PIC WISCONSIN and their ownership
of
PIC WISCONSIN common stock will be set forth in the required fi lings
with
the SEC. You will be able to obtain a free copy of the prospectus/proxy
statement and other documents that contain information regarding
ProAssurance Corporation and PIC WISCONSIN from any
of
these sources: • The Securities and Exchange Commission Web site
(www.sec.gov/index.htm) • PIC WISCONSIN (800.515.0092 or
www.picwisconsin.com) • Frank B. O’Neil, Senior Vice President, Corporate
Communications, ProAssurance Corporation 100 Brookwood Place, Birmingham,
Alabama 35209 or 205.877.4461 Shareholders are urged to read the
proxy
statement/prospectus and the other relevant materials when they become
available before making any voting or investment decision with respect
to
the proposed merger.
|
•
Emphasize oral presentations to the peer review committee. Avoid
submitting documents and written statements to the peer review committee
because the information may not be privileged.
•
Label notes and other committee-created documents “Confi dential: Peer
Review Document.” List relevant statutes on the front page of the
document. • Have the peer review committee orally present its
recommendations to the governing body of the organization. Do not
share
documents that detail the reasons for the conclusions. Any handouts
must
be
collected by the committee at the end of the presentation.
•
Don’t provide details. Governing body minutes should state that the peer
review committee gave its monthly report. Period.
•
Don’t vote. The governing body should take action without voting. Votes
can be considered evidence of collusion.
IN
OR OUT? Many organizations fi nd it diffi cult to provide unbiased
reviews
internally. An effective review avoids confl icts of interest, possible
restraint of trade, and a lack of suffi ciently experienced peers.
Guidelines for internal and external reviews can help make the process
more objective and assure reviewers that their participation will
be seen
as good faith effort that will be immune from lawsuits by the person
reviewed. “In rural areas, for example, it can be difficult to fi nd
reviewers who don’t have a confl ict of interest,” Rausch adds. “The
physicians all know each other and are often part of the same or
competing
practice groups.” Community Access Hospitals (CAHs) often work with
consultants, their medical societies, or larger hospitals in their
networks to fi nd appropriate reviewers. A consultant can be particularly
effective in fi nding neutral peers outside of the immediate area,
helping
a committee formulate the questions a reviewer must answer, and providing
a second layer of review, if, for example, an internal review results
in
an adverse recommendation and the group is concerned that it may
result in
a lawsuit. An external review can be expensive, so is important to
determine its focus up front. “In addition to fairness considerations, you
must include the right expertise,” continues Rausch. “For example, even
though an emergency department physician may be a peer of the person
reviewed, you may wish to include a more specialized reviewer such
as an
interventional cardiologist if the patient safety issues are not
easily
evaluated internally at a strictly peer level. Your ultimate goal
is
to
improve
the quality of patient care.” Rausch concludes, “A review may begin as an
evaluation of one physician’s skills but end up changing the entire
department’s procedures. External reviews, when appropriate,
plus
continued
monitoring of the effects of your peer review actions on your patient
outcomes are your assurance that the organization is not
losing
sight of the big picture of institutional process improvements while
focusing on the competence of individual practitioners.”
1.
Quattrone M. “Is Peer-Review Privilege Eroding?” The Risk
Management Reporter, Vol. 18, No. 6 (Dec. 1999), pp.
3-5.
2.
Becker M. “Peer Review,” PIC WISCONSIN Risk Management
Networking
Group, Madison, WI, April 15, 2005. 3. Bock M. “Physician Peer
Review Process and Procedure,” presentation, Springfi eld, IL, April 27,
2005. 4. Gendleman L. “Peer Review—Credentialing and the National
Practitioner Data Bank,” PIC WISCONSIN Risk Management Networking Group,
Madison, WI, April 15, 2005. PEER REVIEW ESSENTIALS
•
Document the peer review process in your bylaws and
procedures.
•
Have an attorney review your process periodically.
•
Make quality/process improvement the focus throughout
investigations.
•
Be specifi c about the quality, patient safety, or behavioral concerns
that need to be addressed.
•
Consider the full range of options before recommending an
action.
•
Meticulously protect the confi dentiality and integrity of your
investigations. • Consider external and additional reviews where needed to
ensure a fair outcome. TrendWatch is published quarterly and circulated
to
more than 13,000 PIC WISCONSIN policyholders, certifi cate holders,
risk
managers, and shareholders. It is designed to inform readers of issues
and
trends in loss prevention—our ongoing goal at PIC WISCONSIN. We welcome
your comments and suggested topics for future issues. TrendWatch
provides
information of a general nature, and it is not intended as legal
advice or
opinion relative to specifi c matters, facts, situations, or issues.
You
should consult with an attorney about your particular circumstances.
©
2006 PIC WISCONSIN UPCOMING EVENTS February 21: Audioconference:
The Bill
& the Patient: The Impact on Your Practice March 29: Iowa Risk
Management Networking Group: How to Build a Risk Management Program
April
13: Madison Risk Management Networking Group: How to Build a Risk
Management Program April 26: Illinois Risk Management Networking
Group:
How to Build a Risk Managment Program May 16: Audioconference: Claim
and
Legal Process PRSRT STD U.S. POSTAGE PAID MADISON WI
PERMIT
NO. 2106
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