A Hospital in Ohio tried to prevent access to a patient incident report on the basis of Peer Review Privilege. The Hospital claimed that, since the incident report was reviewed by the Hospital Peer Review Committee, the report was then privileged.
In Ridenour v. Glenbeigh Hospital, the Ohio Appellate Court stated that the Ohio Peer Review privilege applied,
only to documents specifically generated by or for a peer review committee
The moral of the story is that you cannot protect other documents created outside of the peer review process simply by inserting them into the peer review process.
