April 20, 2019

Colorado Supreme Court: Quality Management Program Records Protected Since Program Had CDPHE Approval

The Colorado Supreme Court issued its opinion in Simpson v. Cedar Springs Hospital, Inc. on Monday, October 13, 2014.

Quality Management Privilege.

In this original CAR 21 proceeding, the Supreme Court held that the trial court erred in finding that a hospital must have “authoritative” documentation of approval by the Colorado Department of Public Health and Environment (CDPHE) for the quality management privilege under CRS §25-3-109 to apply. The Court held that because the hospital maintained a CDPHE license at all relevant times, its quality management program was necessarily approved by CDPHE, and the documents from its quality management committee meetings were therefore covered by the quality management privilege. The Court made this rule absolute, and remanded to the district court for further proceedings consistent with this opinion.

Summary and full case available here, courtesy of The Colorado Lawyer.

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