DHA-PM 6025.13 - PEER REVIEW HEARING LAWYER
Korody Law has defended healthcare providers in the Army, Navy, Air Force, and National Guard facing clinical adverse privileging actions. This includes uniformed, civilian, and contract providers.
Clinical Adverse Actions and Adverse Privileging Actions for privileged providers are governed by DHA-PM 6025.13, Volume 3 as of October 1, 2019.
Read our Post about DHA-PM 6025.13 Volume 3 and it’s impact on a provider’s rights.
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Summarily suspended? Let Korody Law provide you a free case consultation.
Military Doctor Defense | Clinical Privileging & Adverse Action Attorney
Korody Law, P.A. aggressively defends military doctors, nurses, dentists, pharmacists, psychologists, and other privileged providers facing adverse clinical actions under DHA-PM 6025.13, Volume 3. Attorney Patrick Korody is a former Navy Judge Advocate (Captain, USN Reserve) with more than 20 years of military justice and administrative law experience.
We represent uniformed military healthcare providers, GS civilians, and contractors stationed worldwide.
What We Defend Against
- Summary Suspension of Clinical Privileges
- Quality Assurance Investigations (QAI)
- Peer Review Panel Hearings
- Final Adverse Privileging Actions
- NPDB Reporting and State Board Implications
- Employment Termination / Separation Actions
These actions fall under DHA-PM 6025.13, Vol. 3, the governing policy for clinical adverse actions across the Defense Health Agency.
Why You Need an Experienced Military Healthcare Defense Attorney
The DHA privileging and adverse action process is complex, technical, and can permanently damage a medical career. Consequences include:
- NPDB reports after 30 days of summary suspension
- Long-term impact on credentialing, licensing, and employment
- Separation from military service
- Loss or restriction of clinical privileges
An experienced military attorney helps by:
- Ensuring procedural rights under DHA policies are enforced
- Challenging unsupported allegations of incompetence/misconduct
- Preparing evidence, witnesses, and strategy for hearings
- Appealing adverse findings and NPDB reports
- Protecting your license, career, and livelihood
Consequences of Adverse Privileging Actions
- Suspension, restriction, or revocation of privileges
- Mandatory reporting to the NPDB
- State licensing board notifications
- Civilian employment consequences
- Military separation (ADSEP)
Frequently Asked Questions
What is a summary suspension?
A summary suspension immediately removes clinical privileges pending investigation and often triggers QAI and peer review processes.
Will a summary suspension be reported to the NPDB?
Yes. Suspensions longer than 30 days are reported. Final actions—reinstatement, restriction, revocation—are also reported.
Should I hire an attorney?
Yes. Providers should seek counsel immediately after a summary suspension, QAI notification, or adverse privileging notice.
Can I separate or resign during the process?
Yes, but doing so without providing written notice that you intend to exercise due process rights is dangerous and may result in unchallenged NPDB reports. Additionally, an open investigation normally makes it very difficult to obtain new employment and/or become credentialed at a new hospital.
How Korody Law Protects Your Career
- Review and analyze the QAI and evidence
- Prepare you for testimony and written responses
- Develop a comprehensive defense strategy
- Advocate before Peer Review Panels
- Challenge procedural errors or policy violations
- Appeal adverse privileging determinations
Your clinical privileges and professional reputation are too important to face this alone.
Free Case Consultation
If you are facing a summary suspension or adverse privileging action, contact Korody Law immediately.
Adverse Privileging Action Frequently Asked Questions (FAQ)
What is a summary suspension? A summary suspension is a removal from clinical practice and usually the first indication that the provider is being investigated for clinical incompetence, impairment, or professional misconduct. The provider will receive formal written notice that that includes certain rights as outlined in DHA-PM 6025.13, Volume 3.
Can I quit if I am under a summary suspension? An employee like a contractor or civilian employed “at will” of course can quit. A military member could request to separate. A civilian or military member should rarely quit or separate while under a summary suspension, but this is a very case-by-case determination. Contractors tends to get fired or go into an unpaid status so the decision to quit is often one made for them. Most importantly, any provider under a summary suspensions who ends affiliation (quits, terminated, separated) must, in writing, immediately request that the due process procedures continue. This is normally accomplished by an email or letter to the point of contact identified in the summary suspension.
If I quit before I am placed in a summary suspension, can they investigate me? Not only can you be investigated, they can follow the whole process and seek to adjudicate a final adverse privileging action. If you have ended affiliation and receive notice by mail or email that you are the subject of a quality assurance investigation (QAI) it is important to respond and request due process procedures.
Will the summary suspension be reported to the NPDB? After 30 days, the summary suspension will be reported to the NPDB. A revision-to-report will thereafter be made when the process concludes updating the entry to show the final decision, whether it be reinstatement or a adverse clinical action. I do not believe DHA is following the NPDB regulations with respect to entering and removing summary suspensions from the NPDB and am actively challenging this reporting. In my experience, it is exceedingly rare than a provider is reinstated before the 30 days elapses.
What are my rights in this process? A provider has many rights under DHA-PM 6025.13, Volume 3, though the regulation can be confusing and contradictory in parts. The three most important rights are 1) the right to receive and respond to the QAI before it goes to the privileging authority; 2) the right to appear before a Peer Review Hearing; and 3) the right to appeal the privileging authority’s final decision to the DHA. There are also separate rights under the regulations governing the NPDB to submit a statement or appeal a NPDB entry.
When should I hire a lawyer? You should, at minimum, speak to a lawyer experienced in handling adverse privileging action cases when you receive the summary suspension. You should hire an experienced lawyer if you receive the QAI and finds incompetence, impairment, or misconduct.
How can a lawyer help me? We can assist you in exercising your rights and challenging the allegations made against you. A Peer Review Panel Hearing is like a mini-trial. Evidence is admitted. Witnesses are called. Opening and closing arguments are made. Your lawyer actively represents you and challenges the allegations and proposed adverse clinical action. If an appeal is necessary, your lawyer will obtain and review the hearing transcripts and draft an appeal alleging legal errors in the process and making equity arguments against an adverse clinical action.
The biggest mistake providers make is thinking they can talk their way to immediate reinstatement when notified of a summary suspension of privileges. That "talking" often is more harmful than helpful.
Free Case Consultation
Summarily suspended? Let Korody Law provide you a free case consultation.