The Florida Supreme Court recently overturned a law that had given two Florida hospitals unique authority to disregard their medical staff bylaws.
In late August, the court threw out the St. Lucie County Hospital Governance Law, a 2003 law that applied to the two private hospitals in St. Lucie County, both owned by HCA Inc. of Nashville, Tenn.
Under the special law, the hospital board of directors' bylaws would prevail over the medical staff bylaws on any area of conflict related to medical staff privileges, quality assurance, peer review, and contracts for hospital-based services.
In Lawnwood Medical Center v. Randall Seeger, M.D. (president of the Lawnwood Medical Center medical staff), the Florida Supreme Court upheld a lower court ruling that found that the law was unconstitutional because it granted a “privilege to a private corporation” and violated the constitution's “equal protection” clause by creating two different classes of hospitals in the state.
The Florida Supreme Court concluded that the law granted the management of the hospital “almost absolute power in running the affairs of the hospital, essentially without meaningful regard for the recommendations or actions of the medical staff.”
Since the approval of the medical staff bylaws at the Lawnwood Regional Medical Center in 1993, there had been several disputes between the hospital management and the medical staff regarding issues such as peer review, resulting in multiple lawsuits. After years of conflict, the hospital management sought and received a legislative remedy in 2003.
In an unusual legal move, the hospital management filed a court action shortly after the law went into effect to have it declared “constitutional.” The law was rejected by a trial court and an appellate court before making its way to the Florida Supreme Court this year.
Officials at HCA Inc. are disappointed in the ruling and are reviewing the decision to determine possible next steps, said Nicole Baxter, a spokesperson for HCA.
The American Medical Association praised the decision. “Those bylaws represent a binding contract,” said Dr. Cecil B. Wilson, a board member of the AMA, which filed “friend of the court” briefs in opposition to the 2003 statute through its litigation center.
The AMA litigation center and the Florida Medical Association also provided financial support to defray the legal costs of the medical staff.
By superseding jointly approved bylaws, the hospital was doing a disservice to both its physician staff and patients, Dr. Wilson said. Ignoring medical staff input on issues such as credentialing can have serious implications for safety and quality of care, he said.
Dr. Wilson said the AMA is hopeful that the case will serve as an example around the country, where conflicts between hospital management and medical staffs are becoming more common as both groups try to discharge their responsibilities related to quality and patient safety.