Padmanabhan v. Cambridge Health Commission – (Summary)

NPDB Report Upheld in Massachusetts

A Massachusetts appellate court upheld summary judgment in favor of a hospital that reported a physician’s voluntary resignation to the NPDB after negotiating the physician’s departure and the terminology of the NPDB report with the physician’s attorney.  The court found that while the physician disputed that he “resigned” his privileges, his own counsel negotiated a plan to cancel his medical staff hearing, pending his submission of a resignation letter.  Further, filing of an NPDB report was proper (as determined by the Secretary of the Department of Health and Human Services, which oversees the National Practitioner Data Bank), regardless of whether the physician explicitly resigned or, as he claimed, allowed his appointment and privileges to lapse several months prior (while under investigation).