Semmelweis Society

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Ignaz Semmelweis
Dr. Ignaz Semmelweis (1860 portrait): Obstetrician. Discovered in 1847 that handwashing with a chlorinated-lime solution reduced the incidence of fatal childbed fever tenfold. He was unsuccessful in convincing his contemporaries of the virtues of handwashing. He was confined to a mental institution where he died in 1865.
Dr. Ignaz Semmelweis (1860 portrait): Obstetrician. Discovered in 1847 that handwashing with a chlorinated-lime solution reduced the incidence of fatal childbed fever tenfold. He was unsuccessful in convincing his contemporaries of the virtues of handwashing. He was confined to a mental institution where he died in 1865.
Born July 1, 1818
Tabán, then part of the Austro-Hungarian empire, now Hungary.
Died August 13, 1865
Vienna, Austria
Nationality Hungarian
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The Semmelweis Society, Incorporated is a non-profit organization for physicians formed in California in 1986 by Dr. Verner S. Waite and named after Ignaz Semmelweis. Several hundred doctors have joined the Semmelweis Society to alert the public to the hazards of sham peer review. Past presidents of the Semmelweis Society include Drs. Verner Waite, Henry Butler, C. William Hinnant and Roland Chalifoux.

Semmelweis Society charges nothing for its services; it does welcome donations for its work in the public interest.


Dr. Waite named his organization after Dr. Ignaz Semmelweis of Vienna and Budapest because of the disregard for due process given to his ideas on childbed fever, despite his success preventing it in 1847 with hand-washing a generation before the germ theory of disease.


For years Dr. Waite espoused the importance of fair peer review to protect doctors who protect patients, and he counseled colleagues at a rate of approximately 2 new calls per week for over 20 years.



Victims of “sham” or “bad faith” peer review rarely gain access to any independent due process to challenge this unique form of retaliation, which in many cases results in the end of their careers as physicians. Bad faith peer review against one physician can and does persuade others to remain silent rather than advocate on behalf of their patients. The Semmelweis Society urges integrity in medicine, and an end to sham peer review.


Alan Dershowitz, the Counsel of Record for an amicus brief in a sham peer review case, wrote: the goals of the HCQIA and peer review are undermined, not promoted, when “qualified physicians are punished and excluded from practice because they have chosen to stand up for a patient. Whenever fewer physicians are willing to criticize the medical community out of fear of the dire consequences of a fundamentally unfair, bad faith peer review, an essential prong in the checks and balances integral to a successful health care program will be silenced.”

The Need for Reform: The Health Care Quality Improvement Act (HCQIA) seeks to "improve the quality of medical care" through "effective professional peer review." Unfortunately, a large number of hospitals have learned to exploit the unqualified immunity provisions in the peer review process to punish physician whistleblowers who speak out against hospital practices that threaten the safety of patients and the quality of medial care at the institution.


Without structural accountability, any structure is vulnerable to being exploited for unacceptable hidden agendas. That is what has happened with peer review.


Contents

[edit] Inspiration from the life of Ignaz Semmelweis

The Semmelweis society has taken inspiration from the life of Ignaz Semmelweis, who suffered because he stood up for quality patient care in the 1860s. While working at the Vienna General Hospital in Austria, Semmelweis discovered in 1847 that hand washing with chlorinated lime solutions reduced the incidence of fatal puerperal fever from about 10 percent (range 5-30 percent) to about 1-2 percent.

Semmelweis was outraged by the indifference of the medical profession and began writing open and increasingly angry letters to prominent European obstetricians, at times denouncing them as irresponsible murderers. His contemporaries, including his wife, believed he was losing his mind and he was in 1865 committed to an asylum (mental institution). Semmelweis died there only 14 days later, possibly after being severely beaten by guards.

Years after his death, Semmelweis is considered a pioneer of antiseptic procedures. His life was, according to the Semmelweis Society, an example of a sham peer review defeating the science that could have saved countless lives.

Semmelweis on an Austrian postage stamp issued in 1965 marking the 100th anniversary of his death.
Semmelweis on an Austrian postage stamp issued in 1965 marking the 100th anniversary of his death.


[edit] Synopsis of the life of Ignaz Semmelweis

Ignaz Philipp Semmelweis' (July 1, 1818 - August 13, 1865), also Ignac Semmelweis (born Semmelweis Ignác Fülöp), [1][2] [2] was a Hungarian physician called the "savior of mothers" [3] [4] who discovered, by 1847,[3] that the incidence of puerperal fever could be drastically cut by use of hand washing standards in obstetrical clinics.[3] Puerperal fever (or childbed fever) was common in mid-19th-century hospitals and often fatal, with mortality at 10%-35%. [5] Semmelweis was born July 1, 1818 in Tabán, the oldest sector of what is now Budapest. It was then part of the Austro-Hungarian empire, now Hungary. Some of his teachers included Carl von Rokitansky, Josef Skoda and Ferdinand von Hebra. It was at the Vienna General Hospital that Semmelweis began investigating the causes of puerperal fever. Semmelweis was puzzled, that only a few of these women contracted puerperal fever. "To me, it appeared logical that patients who experienced street births would become ill at least as frequently as those who delivered in the clinic. [...] What protected those who delivered outside the clinic from these destructive unknown endemic influences?"[6].

The only major difference was the individuals who worked there. The First Clinic was the teaching service for medical students, while the Second had been selected in 1841 for the instruction of midwives only.


He concluded that he and the medical students carried the infecting particles on their hands from the autopsy room to the patients they examined in the First Obstetrical Clinic. Midwife students in the second clinic were not engaged in autopsies and had no contact with corpses which explained the lower mortality rate there. The germ theory of disease had not yet been developed at the time. Thus, Semmelweis concluded that some unknown "cadaverous material" caused childbed fever. He instituted a policy of using a solution of chlorinated lime for washing hands between autopsy work and the examination of patients and the mortality rate dropped an order of magnitude, comparable to the Second Clinic's. The mortality rate in April 1847 was 18.3 percent, handwashing was instituted mid-May, the rates in June were 2.2 percent, July 1.2 percent, August 1.9 percent.

[edit] Semmelweis Society: The Early Years Under Dr. Verner Waite

Dr. Waite formed the Semmelweis Society after he won a lawsuit against two colleagues who harassed him with their control of a hospital's Tissue Committee. The same year that Dr. Waite won his lawsuit in California, Congress passed the Health Care Quality Improvement Act of 1986, probably in response to another lawsuit, PATRICK v. Burget in Astoria, Oregon. The ensuing Data Bank and the omission of due process from that law invited nationwide abuse of physicians´ property rights, i.e. their property interest in their reputation.

As Dr. Waite stated, he would not be able to win a lawsuit today because of HCQIA. With physicians being labeled "disruptive" for whistleblowing about unsafe conditions in hospitals, the attraction of a U.S. medical career is in doubt. The USA faces a shortage of physicians and it allows Medicare taxes to support hospitals which permit their employees to libel physicians. This arrangement is not in the public interest and it is not a formula likely to attract the ´Best and the Brightest´ Americans to become or to remain physicians in this country. The solution is to take the money out of bad faith peer review by demanding due process as a condition of Medicare payment. See www.SemmelweisSociety.net and www.Semmelweis.org.

"Six of my cases were brought up for review by a tissue committee controlled by competitors. A nurse (sic), employed by the Saint Francis Hospital, testified that I had the highest rate of complication. Why such testimony was admitted is a matter of some interest, in itself. Liability for bearing false witness is an important related matter, in itself, and falls under the topic of immunity. Under our gracious new laws, I would not be able to win $500,000 today were a nurse again caught committing libel." Verner S. Waite M.D., FACS

[edit] 1993 article challenges Due Process in Medical Peer review

In 1993 the following article by a doctor and a lawyer appeared in the March issue of the Southern Medical Journal:

"SHOULD DUE PROCESS BE PART OF HOSPITAL PEER REVIEW?

Medical peer review is the process by which a committee of physicians investigates the medical care rendered by a colleague in order to determine whether accepted standards of care have been met. The professional or personal conduct of a physician may also be investigated. If the committee finds that the physician departed from accepted standards, it may recommend limiting or terminating the physician's privileges at that institution. If the physician's privileges are restricted for more than 30 days, federal law requires the peer review committee to report that fact to the National Practitioner Data Bank (1).


[edit] No Federal Statute protects Due Process for Doctors or Patients

There is no federal statute that requires peer review committees to observe due process, which the Supreme Court has defined as (1) giving written notice of the actions contemplated, (2) convening a hearing, (3) allowing both sides to present evidence at the hearing, and (4) having an independent adjudicator (2). Prior to the Health Care Quality Improvement Act of 1986 (HCQIA) (3), the effects of an adverse peer review finding were restricted to the hospital involved. Because the HCQIA mandates the reporting of disciplinary actions of peer review committees to the National Practitioner Data Bank, such a report could harm a physician's career throughout the nation (1-4).

Peer review in its current form fails to protect an investigated physician from committee members having an economic or personal bias. Economic bias occurs when a committee member has a financial interest in the outcome. If the challenged physician is a partner or associate, any error that he may have made is likely to be considered to have been unavoidable. On the other hand, peer review has already been used to force a competing physician out of practice (9). Such economic bias denies due process (10). The United States Supreme Court struck down a decision from Ohio's municipal court system in which the judge was partly paid from the fines he assessed. The Court found that the system gave an incentive to rule one way rather than the other (10).


Personal bias is inevitable when coworkers judge each other. Some people are very likable, and others illuminate the room by their absence.


Federal law prohibits a federal judge from hearing cases in which his impartiality might reasonably be questioned or in which he has a financial interest (11). The same standards should apply to member of a peer review committee. The potential for abuse when these suggested procedures are not followed would indicate the need for mandatory due process.


Due process, which is designed to limit these abuses, is not required by the Constitution of the United States unless there is government action that affects a liberty or property right (12,13). The case of PAUL v DAVIS illustrates the legal meaning of property rights as applied to employment (14). The police labeled the plaintiff as a shoplifter and advised local businesses to watch him carefully. The plaintiff sued, claiming that the government was injuring his reputation without due process. The Supreme Court ruled against the plaintiff, but stated that should there be an effect on employment, then such injury would invoke the constitutional protection (14).


The sole reason for reporting the results of peer reviews is to restrict the practices of incompetent physicians. Congress cited the following as the very reason for the act: 'There is a national need to restrict the ability of incompetent physicians to move from state to state without disclosure or discovery of the physicians'...incompetent performance (15).'


The right to practice medicine without a governmental agency erroneously reporting that a physician has been deficient in his actions is a constitutional property right. Rights, even constitutional rights, can be waived by express agreement, or by the failure to assert those rights. State institutions, however, may not make waiver of a constitutional right a condition for employment (16).


Medical peer review is usually based on the screening of medical records, which places physicians with poor record-keeping skills at a disadvantage, and ignores the fact that medical records are often a poor indicator of the quality of care (5). Additionally, there is no requirement that the physician be given notice and an opportunity to be heard, and there is no requirement that members of the peer review committee be unbiased. The HCQIA recommends that the physician should get notice of the allegations, time to prepare for a hearing, a list of witnesses, the right to legal counsel, and an impartial fact finder. However, the act concludes "A professional review body's failure to meet the conditions described in this subsection shall not, in itself, constitute failure to meet the standards of this act)." This failure of the HCQIA to require due process calls into question the fundamental fairness of the medical peer review system.


The reason that due process should be a part of any fact-finding endeavor was stated by Justice Goldberg in SILVER v NEW YORK STOCK EXCHANGE:


'Experience teaches...that the affording of procedural safeguards, which by their nature serve to illuminate the underlying facts, in itself often operates to prevent erroneous decisions on the merits from occurring (7).'


The purpose of requiring due process is to ensure that the actions taken are not arbitrary, capricious, or unreasonable. Where there is no due process, the system invites abuse (8).


[edit] Semmelweis Society Joins Forces with Public advocates

Dr. Ignaz Semmelweis (in door opening surrounded by students) demands hand wash procedure with a chlorinated-lime solution before obstetrical students undertake vaginal examination of a pregnant woman, probably 1850-1860.
Dr. Ignaz Semmelweis (in door opening surrounded by students) demands hand wash procedure with a chlorinated-lime solution before obstetrical students undertake vaginal examination of a pregnant woman, probably 1850-1860.

From the beginning, the Semmelweis Society knew they faced an uphill battle to change the status quo. Entrenched hospital interests opposed any change in the Health Care Quality Improvement act (HCQIA). To bring the difficult challenge to the attention of Congress and to the public, the Semmelweis Society joined forces with the Government Accountability Project (GAP), legal director Tom Devine, and with 42 other coalitions comprising the "Make it Safe" good government group. Senator Charles Grassley and former Congressman Rev. Rev. Walter E. Fauntroy have been champions of due process in medical peer review, and consistently supported protections for medical whistleblowers.

In 2007, Dr. James Murtagh of the Semmelweis group helped to found the first ever "Whistleblower Week in Washington." In 2008, the meeting of doctors and whistleblowers expanded with the formation of the "International Association of Whistleblowers (IAW)" co-chaired by Dr. James Murtagh and Mr. Michael McCray, Esq.


[edit] Sham peer review in medicine

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A 2006 New England Journal of Medicine article notes that "patient-safety experts stress that complex, error-prone systems are at the root of most mistakes in health care. A major goal of contemporary patient-safety programs is to encourage a culture of safety and create a blame-free environment in which errors are seen as a by-product of bad systems, not as caused by bad or incompetent people. [7][8]

Hospitals also attempt to blame physicians for potential system failures (that have come under scrutiny). In the latter situation, "errors" are cited which have no associated adverse outcomes. [9] In both situations, scapegoating is the reason for the sham peer review. This situation appears to be an outgrowth of the legally contentious atmosphere of healthcare in the 21st century.

Physicians who point out true (or potential) system failures in healthcare institutions, either from within the institution or to external evaluators, have been labeled as whistleblowers. A whistleblower is an employee or former employee or patient or citizen who reports misconduct to people or entities that have the power and presumed willingness to take corrective action. Many whistleblowers have objected to the term "whistle-blower," as being pejorative, and have suggested different terms, such as a "lamplighter" (Frank Serpico) or "truth teller" (Jeffrey Wigand). Generally, the whistle-blower reports a violation of law, rule, regulation and/or a direct threat to public interest, such as fraud, health/safety violations, and corruption. The Semmelweis Society has joined forces with whistleblowers from across American society, highlighting the adversities that doctor whistleblowers share with other whistleblowers.

In many cases, the Semmelweis has objected to the lack of due process at state medical boards. Texas Medical Board Watch has highlighted problems in Texas, and Dr. Gil Mileikowsky has spotlighted problems at the Medical Board of California.

Senator Grassley often states that medical whistle-blowers are "about as welcome as a skunk as a picnic," but vital to the nation's security.

Paul Revere is named America's first whistleblower.
Paul Revere is named America's first whistleblower.
 The neutrality of this article is disputed.
Please see the discussion on the talk page.(December 2007)
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Chuck Grassley
Semmelweis Society
Website United States Senator Chuck Grassley of Iowa
Walter Edward Fauntroy
Semmelweis Society
Profession Pastor, activist, whistleblower and doctor advocate


Poster in support of whistleblower legislation
Poster in support of whistleblower legislation
Abraham Lincoln, original author of laws to protect whistleblowers. The "Lincoln Laws were critical to the success of Dr. Patrick Campbell.
Abraham Lincoln, original author of laws to protect whistleblowers. The "Lincoln Laws were critical to the success of Dr. Patrick Campbell.


Lawrence R. Huntoon, chairman of the Association of American Physicians and Surgeons Committee to Combat Sham Peer Review, states that sham peer review is a tactic that is being increasingly employed as a retaliation against physicians whom the hospital regards to be whistleblowers. He distinguishes sham peer review, or "peer review done in bad faith for some purpose other than the furtherance of quality care", from good-faith peer review, or "peer review done in furtherance of the goal of improving the quality of care."[10]

[edit] Potential conflicts of interest between Hospital and Medical Staff

Most medical staff bodies utilize the hospital attorney and accept hospital funds to try peer review cases. Although the hospital and medical staff are technically independent entities, this independence is lost by this arrangement. In Sham Peer Review, the hospital, through its shared attorney, unduly influences the outcome of the proceeding. This effectively negates the independence of the medical staff.

Hospital administrators or physicians in positions of power (often board members) often attend seminars to learn legal techniques to influence peer review outcomes. Colloquially these have become known as Horty Springer techniques.[11] These large multi-state law firms, such as Davis, Wright, and Tremaine[12] and Foley and Lardner,[13] specialize in racketeering and labor disputes and have both attacked and defended racketeering cases and therefore accumulated extensive experience in these fields.

The California Medical Association and others have strongly advocated against this practice and warns medical staffs about its dangers. California has enacted legislation formally requiring the separation of the hospital and medical staff.[14]

[edit] Major Advocates of the Semmelweis Society

o Physicians Dr. Patrick Campbell and Dr. Lokesh B. Vuyyuru blew the whistle on unscrupulous hospital companies such as Tenet Healthcare and HCA who put profit before patients. Dr. Campbell informed the FBI of unnecessary open heart surgery and other cardiac procedures being done at Tenet-owned Redding Medical Center, which bilked the federal government hundreds of millions of dollars.

o Dr. Gil Mileikowsky, president of the Alliance For Patient Safety, has sponsored the concept of the "Clean Hands Award," yearly given to doctors and journalists who have made contributions in the fight to restore integrity to hospital peer review. Dr. Mileikowsky has been involved in extensive litigation, including an appeal to the Supreme Court.

o Dr. Blake Moore chaired the 2008 meeting of Semmelweis.

o George E. Holmes, Ph.D. brought his considerable skills from the American Association of University Professors (AAUP) to become the long term treasurer and webmaster of Semmelweis. Recently, Dr. Holmes obtained recognition for Semmelweis by obtaining CME credit for Semmelweis meetings.

o Arthur S. Shorr and Robert Liles, Esq. have served as long term advisors to Semmelweis.

o Roland Chalifoux DO - Neurosurgeon, President of the Semmelweis Society, helped to coin the term "sham peer review."

o Dr. Ralph Bard, former vice president of Semmelweis, helped to write bylaws of Semmelweis.

o Michael Bennett - President of the Coalition for Patients' Rights (CPR). Mr. Bennett lost his father due to an infection he received at the hospital. Mr. Bennett is a nationally recognized patient safety advocate.

o Dr. Jay Jayasankar has developed innovative models to reform peer review.

o Joe Flores, Esq has developed new legal techniques to combat sham peer review.

o John Schilling, a co-winner in the largest fraud case in US history, the $1.7 Billion dollar Health Corporation of America (HCA) case, introduced his new book. Mr. Schilling was joined by many of the other most successful winners in urging an end to fraud against patients.

o Mr. Tom Devine, legal director of the Government Accountability Project, held an in depth Congressional legal briefing, and together with top public interest groups, gave special awards to Congressional leaders and staffers who oppose fraud and support doctors of integrity.

o Religious leaders, including Rev. Walter E. Fauntroy, stressed the role of speaking the truth and the role of faith based initiatives in America's civil rights heritage, and drew parallels to the Semmelweis struggle.


In 2003 Semmelweis Society International, Incorporated was formed in Tennessee, with Dr. Waite's approval. Ralph Bard M.D., J.D., FACS, William Hinnant M.D., J.D., DABU, and Henry Butler M.D., FACS were the incorporators.

The word "International" was chosen to draw attention to the fact that we are all patients, that physicians are needed everywhere, and that they should pay attention to due-process peer review as part of professionalism when they decide where to study, to live, and to practice medicine, because other countries do not have the abuse of power found in the USA under HCQIA.

Several hundred doctors have joined the Semmelweis Society International to alert the public to the hazards of sham peer review.


It is the intent of Semmelweis Society International to write sample by-laws for physicians to use as a guide when deciding where it is safe to practice medicine in the USA today, and to help physicians locate such sites, whether here or abroad.

[edit] Medical Whistleblowers Demand Reform

Doctors have become active in whistleblower cases, and 80% of fraud is now reported in hospital related Qui Tam suits. Doctors noted that they were often subjected to "sham peer reviews" and their careers were jeopardized if they stood up for their patients or reported corruption within HMOs. Dr. Larry Poliner was noted as an outstanding example of a doctor who stood up for his patients, and suffered massive retaliation, leading a jury to eventually award a $366,000,000 verdict. Dr. Vuyyuru won the first Sham peer review case in 1998 at Richmond, Virginia. The hospital did the sham peer review expunged the sham peer review documents, Apologized in writing and paid an undisclosed amount of money as part of settlement.


Dr. Chalifoux pointed out that sham peer review resulted in doctor shortages, lack of access to care, decreased competition, decreased safety, and protected "Big Medicine" HMOs from the consequences of medical errors and corruption. Dr. Helen Salsbury writes she had been subjected to retaliation for decreasing the C-section rate in her community from 50% to 10%. Doctors also presented the consensus that sham peer review was typically used to silence some of America's best doctors, and needed to be recognized as a prohibited retaliation. Other Doctors testified that minority physicians are singled out for particularly brutal retaliations when they stand up for quality patient care. Evidence was presented that a doctor exposed to sham peer review had a 80% chance of never returning to work. A 20% rate of suicide was found in the group of doctors falsely accused of peer review violations.

Dr. Brian Conner has long advocated the use of Qui Tam laws to protect doctors against sham peer review. Qui Tam laws, also known as the "Lincoln laws" are designed to protect whistleblowers, and to stop fraud against the federal government.


Steve Twedt, the ground breaking investigative journalist, documented the harm of sham peer review. He wrote a series of articles[15] that concluded, "physicians who are wrongly or maliciously accused may be pulled into a hearing where they have no legal representation and no opportunity to face their accusers. Or, in some cases, their accusers sit on the panel investigating them."


"The assumption that peer review is always only about quality and not about economic or intra-professional political struggles is less and less realistic as the economics of the health care industry become more competitive," said Sallyanne Payton, a University of Michigan health law professor


Members of the Veterans Affairs Whistleblowers Coalition, presented sobering data showing the failure of governmental agencies to protect whistleblowers' rights. The doctors asserted that the Department of Veterans Affairs continues to "discourage the reporting of poor quality care by harassing" healthcare workers who provide quality care for veterans.

[edit] Semmelweis Society Plan for Reform

The Semmelweis society joined forces with GAP, WWW and the IAW in 2008, and unanimously adopted a plan for reform, and urged Congress to explore ways to prevent the misuse of peer review, including:

1. Launch a Government Accountability Office investigation to assess the vulnerability and extent of hospitals abusing the peer review process to retaliate against physician whistleblowers.

2. Conduct oversight hearings for a public forum on any significant GAO findings. Collectively with our partners in this area, we have heard the stories of hundreds of physician whistleblowers whose careers have been ruined because they chose to advocate for patient safety or challenged inadequate care at hospitals. These individuals are ready and willing to bear witness with first-hand accounts of their experiences.

3. Amend the HCQIA to help curb abuses of the peer review process. One possibility would be to add an affirmative defense of “whistleblower retaliation” to the HCQIA. A physician could then take this claim to an outside body, which could make a ruling as to whether whistleblower retaliation was a contributing factor in any employment decision. This type of independent review is necessary, and is similar to steps Congress is on the verge of taking to reform the security clearance process for national security employees.

4. Pass H.R. 4047, the Private Sector Whistleblower Protection Streamlining Act of 2007. Introduced by Reps. Lynn Woolsey and Education and Labor Committee Chairman George Miller, this legislation would streamline protections for all private sector employees, and protect physicians who are retaliated against for blowing the whistle on inadequate health care.

5. Pass H.R. 4650, the Congressional Disclosures Act of 2007. The legislation, introduced by Rep. Al Wynn, would give federal workers, contractors, and any other employee of an organization that receive payments from the federal government, including hospitals, access to court when they are prosecuted or otherwise harassed for blowing the whistle directly to Congress.


GAP is also pushing for this expansive definition of employee to be included in congressional efforts to overhaul protections for contractors in H.R. 985, Rep. Waxman's whistleblower legislation, which passed the House in March, and is soon to be reconciled with Senate whistleblower legislation.

Patients, citizens and taxpayers all have a stake in protecting the nation's health system. The inspiration of Ignaz Semmelweis was alive at this expanding annual event.


The officers of Semmelweis agree: "Really great doctors have always been willing to buck the system to stand up for their patients. Dr. Semmelweis was great because he spoke truth to power. Today's doctors must do no less."


[edit] References

1. Health Care Quality Improvement Act of 1986, 42 USC &11133

2. VITEK v JONES, 445 US 480 (1980)

3. Health Care Quality Improvement Act of 1986, 42 USC &11101

4. Iglehart JK: Congress moves to bolster peer review: the health care quality improvement act of 1986. N Eng J Med 1987; 316:960-964

5. Steffen GE: Quality medical care, a definition. JAMA 1988; 260:56-61

6. Health Care Quality Improvement Act of 1986, 42USC &11112(b)

7. SILVER v NEW YORK STOCK EXCHANGE, 373 US 341(1963)

8. BOARD OF REGENTS v ROTH, 408 US 564 (1972)

9. Green R: Hospital peer review in a hostile environment. J Med Assoc Ga

1987; 76:138-140

10. TUMEY v OHIO, 273 US510 (1927)

11. 28 USC $455

12. US Constitution, Amend XIV

13. Board of Regents v. Roth, 408 US 564 (1972)

14. Paul v Davis, 424 US 693 (1976)

15. 42 USC $11101(2)

16. Rutan v Republican Party of Illinois, 110 SC: 2729 (1990)

17. New York State Laws of 1986, Chapter 266

18. O'Keefe DE, Conway GL: Physician discipline and professional conduct.

19. Vuyyuru v. Metropolitan Hosp., 1998 WL 972210

NY State J Med 1988; 88:146-148"

  • Carter, K. Codell; Barbara R. Carter (February 1, 2005). Childbed fever. A scientific biography of Ignaz Semmelweis. Transaction Publishers. ISBN 978-1412804677. 
  • Nuland, Sherwin B, The Doctors' Plague: Germs, Childbed Fever, and the Strange Story of Ignác Semmelweis, 2003.
  • Semmelweis, Ignaz; K. Codell Carter (translator and extensive foreword) (1861). Etiology, Concept and Prophylaxis of Childbed Fever. University of Wisconsin Press, September 15, 1983. ISBN 0299093646. 

[edit] Further reading

[edit] External links


^ Testimony of Linda Peeno, MD about Managed Care in the Healthcare Industry - May 30, 1996 ^ "Humana issues statement on Moore's 'Sicko'", Business First, 2007-06-28. Retrieved on 2007-07-07.

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