Health Care Quality Improvement Act of 1986

In Fahlen v. Sutter Central Valley Hospitals, the California Supreme Court found:

  1. A physician is not required to first exhaust his administrative remedies through the medical staff appeals process in order to challenge sham peer review as whistleblower retaliation; and
  2. Dr. Fahlen qualified as a whistleblower for purposes of the California Whistleblower Act.

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