Ohio Rev. Code » Chapter 2305
Ohio Revised Code

Ohio Rev. Code § 2305.25 (2026)

Peer review committee definitions

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Effective:
September 17, 2014
Latest Legislation:
House Bill 493 - 130th General Assembly
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As used in this section and sections 2305.251 to 2305.253 of the Revised Code:

(A)(1) "Health care entity" means an entity, whether acting on its own behalf or on behalf of or in affiliation with other health care entities, that conducts as part of its regular business activities professional credentialing or quality review activities involving the competence of, professional conduct of, or quality of care provided by health care providers, including both individuals who provide health care and entities that provide health care.

(2) "Health care entity" includes any entity described in division (A)(1) of this section, regardless of whether it is a government entity; for-profit or nonprofit corporation; limited liability company; partnership; professional corporation; state or local society composed of physicians, dentists, optometrists, psychologists, or pharmacists; accountable care organization; other health care organization; or combination of any of the foregoing entities.

(B) "Health insuring corporation" means an entity that holds a certificate of authority under Chapter 1751. of the Revised Code. "Health insuring corporation" includes wholly owned subsidiaries of a health insuring corporation.

(C) "Hospital" means any of the following:

(1) An institution that has been registered or licensed by the department of health as a hospital;

(2) An entity, other than an insurance company authorized to do business in this state, that owns, controls, or is affiliated with an institution that has been registered or licensed by the department of health as a hospital;

(3) A group of hospitals that are owned, sponsored, or managed by a single entity.

(D) "Incident report or risk management report" means a report of an incident involving injury or potential injury to a patient as a result of patient care provided by health care providers, including both individuals who provide health care and entities that provide health care, that is prepared by or for the use of a peer review committee of a health care entity and is within the scope of the functions of that committee.

(E)(1) "Peer review committee" means a utilization review committee, quality assessment committee, performance improvement committee, tissue committee, credentialing committee, or other committee that does either of the following:

(a) Conducts professional credentialing or quality review activities involving the competence of, professional conduct of, or quality of care provided by health care providers, including both individuals who provide health care and entities that provide health care;

(b) Conducts any other attendant hearing process initiated as a result of a peer review committee's recommendations or actions.

(2) "Peer review committee" includes all of the following:

(a) A peer review committee of a hospital or long-term care facility or a peer review committee of a nonprofit health care corporation that is a member of the hospital or long-term care facility or of which the hospital or facility is a member;

(b) A peer review committee of a community mental health center;

(c) A board or committee of a hospital, a long-term care facility, or other health care entity when reviewing professional qualifications or activities of health care providers, including both individuals who provide health care and entities that provide health care;

(d) A peer review committee, professional standards review committee, or arbitration committee of a state or local society composed of members who are in active practice as physicians, dentists, optometrists, psychologists, or pharmacists;

(e) A peer review committee of a health insuring corporation that has at least a two-thirds majority of member physicians in active practice and that conducts professional credentialing and quality review activities involving the competence or professional conduct of health care providers that adversely affects or could adversely affect the health or welfare of any patient;

(f) A peer review committee of a health insuring corporation that has at least a two-thirds majority of member physicians in active practice and that conducts professional credentialing and quality review activities involving the competence or professional conduct of a health care facility that has contracted with the health insuring corporation to provide health care services to enrollees, which conduct adversely affects, or could adversely affect, the health or welfare of any patient;

(g) A peer review committee of a sickness and accident insurer that has at least a two-thirds majority of physicians in active practice and that conducts professional credentialing and quality review activities involving the competence or professional conduct of health care providers that adversely affects or could adversely affect the health or welfare of any patient;

(h) A peer review committee of a sickness and accident insurer that has at least a two-thirds majority of physicians in active practice and that conducts professional credentialing and quality review activities involving the competence or professional conduct of a health care facility that has contracted with the insurer to provide health care services to insureds, which conduct adversely affects, or could adversely affect, the health or welfare of any patient;

(i) A peer review committee of any insurer authorized under Title XXXIX of the Revised Code to do the business of medical professional liability insurance in this state that conducts professional quality review activities involving the competence or professional conduct of health care providers that adversely affects or could affect the health or welfare of any patient;

(j) A peer review committee of the bureau of workers' compensation or the industrial commission that is responsible for reviewing the professional qualifications and the performance of providers certified by the bureau to participate in the health partnership program or of providers conducting medical examinations or file reviews for the bureau or the commission;

(k) Any other peer review committee of a health care entity.

(F) "Physician" means an individual authorized to practice medicine and surgery, osteopathic medicine and surgery, or podiatric medicine and surgery.

(G) "Sickness and accident insurer" means an entity authorized under Title XXXIX of the Revised Code to do the business of sickness and accident insurance in this state.

(H) "Tort action" means a civil action for damages for injury, death, or loss to a patient of a health care entity. "Tort action" includes a product liability claim, as defined in section 2307.71 of the Revised Code, and an asbestos claim, as defined in section 2307.91 of the Revised Code, but does not include a civil action for a breach of contract or another agreement between persons.

(I) "Accountable care organization" means such an organization as defined in 42 C.F.R. 425.20.
Notes of Decisions
Cited in 60 cases (8 in the last 5 years), 1979–2026 · leading case: Browning v. Burt, 613 N.E.2d 993 (Ohio 1993).
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Browning v. Burt, 613 N.E.2d 993 (Ohio 1993). · cites it 8× “VI R.C. 2305.25 SEMC and amicus curiae, Ohio Hospital Association, suggest that hospitals are immune from liability for the acts, omissions and decisions of their peer review committees by virtue of R.”
Dresher v. Burt, 75 Ohio St. 3d 280 (1996). · cites it 3× “R.C. 2305.25 does not provide a hospital with immunity from liability for the hospital's negligence in granting and/or continuing the staff privileges of an incompetent physician.”
Cousino v. Mercy St. Vincent Med. Ctr., 2018-Ohio-1550, 111 N.E.3d 529. · cites it 7× “25(D) (defining an "incident report or risk management report" as "a report of an incident involving injury or potential injury to a patient * * * that is prepared by or for the use of a peer review committee of a health care entity and is within the scope of the functions of…”
Brooks v. Ohio State Univ., 676 N.E.2d 162 (Ohio Ct. App. 10th Dist. 1996). · cites it 8× “Prior to the hearing, appellee filed a motion for partial summary judgment, based on the immunity that peer review/quality assurance committee members are entitled to under R.C. 2305.25 and Section 11111, Title 42, U.”
Wall v. Ohio Permanente Med. Grp., Inc., 695 N.E.2d 1233 (Ohio Ct. App. 8th Dist. 1997). · cites it 12× “OPMG responds that this court should extend the protection of R.C. 2305.25 to peer review committees of professional physician corporations.”
Gates v. Brewer, 442 N.E.2d 72 (Ohio Ct. App. 10th Dist. 1981). · cites it 9× “Plaintiffs argue that R.C. 2305.25 and 2305.251violate the Equal Protection Clause contained in the Fourteenth Amendment to the United States Constitution by granting a special privilege and immunity to negligent physicians whose negligence is the subject of disciplinary action…”
Jacobs v. Frank, 573 N.E.2d 609 (Ohio 1991). · cites it 4× “Our disposition of this case begins with a determination *113 as to whether Frank has a qualified privilege pursuant to R.C. 2305.25 that protects the statements he wrote in his October 25 letter.”
Trangle v. Rojas, 782 N.E.2d 617 (Ohio Ct. App. 8th Dist. 2002). · cites it 5× “{¶ 26} The Ohio Supreme Court has stated: “The purposes of R.C. 2305.25 are clear. The statute extends limited protection to those who provide information to certain review boards and committees to encourage the free flow of information without threat of reprisal in the form of…”
Young v. Durrani, 2016-Ohio-5526, 61 N.E.3d 34. · cites it 3× “113(C), the medical statute of repose, and R.C. 2305.25,2 the medical peer-review statute, were unconstitutional.”
Gureasko v. Bethesda Hosp., 689 N.E.2d 76 (Ohio Ct. App. 1st Dist. 1996). · cites it 8× “This statute provides: “No hospital * * * shall be liable in damages to any person for any acts, omissions, decisions, or other conduct within the scope of the functions of the [professional review] committee.”
Wilson v. Barnesville Hosp., 783 N.E.2d 554 (Ohio Ct. App. 7th Dist. 2002). · cites it 5× “{¶20} The Ohio Supreme Court has stated, “The purposes of R.C. 2305.25 are clear. The statute extends limited protection to those who provide information to certain review boards and committees to encourage the free flow of information without threat of reprisal in the form of…”
Manley v. Heather Hill, Inc., 885 N.E.2d 971 (Ohio Ct. App. 11th Dist. 2007). · cites it 4× “) {¶ 17} R.C. 2305.25(D) defines an “incident report” as “a report of an incident involving injury or potential injury to a patient as a result of patient care provided by health care providers, including both individuals who provide health care and entities that provide health…”
Show all 60 citing cases →
Ohio Rev. Code § 2305.25(A): 2 cases
Wall v. Ohio Permanente Med. Grp., Inc., 695 N.E.2d 1233 (Ohio Ct. App. 8th Dist. 1997). “OPMG responds that this court should extend the protection of R.C. 2305.25 to peer review committees of professional physician corporations.”
Shahbabian v. Trihealth, Inc., No. 1:18-cv-00790 (S.D. Ohio July 22, 2021).
Ohio Rev. Code § 2305.25(A)(1): 3 cases
Vistein v. Am. Registry of Radiologic Technologists, 509 F. Supp. 2d 666 (N.D. Ohio 2007).
Cleveland Clinic Health Sys.—East Region v. Innovative Placements, Inc., 283 F.R.D. 362 (N.D. Ohio 2012).
Talwar v. Catholic Healthcare Partners, 258 F. App'x 800 (6th Cir. 2007).
Ohio Rev. Code § 2305.25(B): 1 case
Huntsman v. Aultman Hosp., 2011-Ohio-1208.
Ohio Rev. Code § 2305.25(D): 7 cases
Manley v. Heather Hill, Inc., 885 N.E.2d 971 (Ohio Ct. App. 11th Dist. 2007). “) {¶ 17} R.C. 2305.25(D) defines an “incident report” as “a report of an incident involving injury or potential injury to a patient as a result of patient care provided by health care providers, including both individuals who provide health care and entities that provide health…”
Cousino v. Mercy St. Vincent Med. Ctr., 2018-Ohio-1550, 111 N.E.3d 529. “25(D) (defining an "incident report or risk management report" as "a report of an incident involving injury or potential injury to a patient * * * that is prepared by or for the use of a peer review committee of a health care entity and is within the scope of the functions of…”
Bailey v. Manor Care of Mayfield Hts., 2013-Ohio-4927.
Ward v. Summa Health Sys., 920 N.E.2d 421 (Ohio Ct. App. 9th Dist. 2009).
Flynn v. Univ. Hosp., Inc., 876 N.E.2d 1300 (Ohio Ct. App. 1st Dist. 2007).
Ohio Rev. Code § 2305.25(E): 14 cases
Cousino v. Mercy St. Vincent Med. Ctr., 2018-Ohio-1550, 111 N.E.3d 529. “25(D) (defining an "incident report or risk management report" as "a report of an incident involving injury or potential injury to a patient * * * that is prepared by or for the use of a peer review committee of a health care entity and is within the scope of the functions of…”
Flynn v. Univ. Hosp., Inc., 876 N.E.2d 1300 (Ohio Ct. App. 1st Dist. 2007).
Fravel v. Columbus Rehab. & Subacute Inst., 2016-Ohio-5807, 70 N.E.3d 1161.
Evans v. Summit Behavorial Healthcare, 2016-Ohio-5857, 70 N.E.3d 1217.
Triplett v. Univ. Hosps. Cleveland Med. Ctr., 2022-Ohio-3553, 197 N.E.3d 1030.
Ohio Rev. Code § 2305.25(E)(1): 11 cases
Fravel v. Columbus Rehab. & Subacute Inst., 2016-Ohio-5807, 70 N.E.3d 1161.
Cousino v. Mercy St. Vincent Med. Ctr., 2018-Ohio-1550, 111 N.E.3d 529. “25(D) (defining an "incident report or risk management report" as "a report of an incident involving injury or potential injury to a patient * * * that is prepared by or for the use of a peer review committee of a health care entity and is within the scope of the functions of…”
Cook v. Toledo Hosp., 862 N.E.2d 181 (Ohio Ct. App. 6th Dist. 2006).
Bailey v. Manor Care of Mayfield Hts., 2013-Ohio-4927.
Manley v. Heather Hill, Inc., 885 N.E.2d 971 (Ohio Ct. App. 11th Dist. 2007). “) {¶ 17} R.C. 2305.25(D) defines an “incident report” as “a report of an incident involving injury or potential injury to a patient as a result of patient care provided by health care providers, including both individuals who provide health care and entities that provide health…”
Ohio Rev. Code § 2305.25(E)(1)(a): 6 cases
Giusti v. Akron Gen. Med. Ctr., 896 N.E.2d 769 (Ohio Ct. App. 9th Dist. 2008).
Large v. Heartland-Lansing of Bridgeport Ohio, L.L.C., 2013-Ohio-2877.
Talwar v. Catholic Healthcare Partners, 258 F. App'x 800 (6th Cir. 2007).
Spurgeon v. Mercy Health-Anderson Hosp., L.L.C., 2020-Ohio-3099, 155 N.E.3d 103.
Triplett v. Univ. Hosps. Cleveland Med. Ctr., 2022-Ohio-3553, 197 N.E.3d 1030.
Ohio Rev. Code § 2305.25(E)(2): 1 case
Cousino v. Mercy St. Vincent Med. Ctr., 2018-Ohio-1550, 111 N.E.3d 529. “25(D) (defining an "incident report or risk management report" as "a report of an incident involving injury or potential injury to a patient * * * that is prepared by or for the use of a peer review committee of a health care entity and is within the scope of the functions of…”
Ohio Rev. Code § 2305.25(E)(2)(a): 2 cases
Stull v. Summa Health Sys., 2024-Ohio-5718, 253 N.E.3d 107.
Holland v. Dayton Child.'s Hosp., 2026-Ohio-1678.
Ohio Rev. Code § 2305.25(E)(2)(c): 4 cases
Stull v. Summa Health Sys., 2024-Ohio-5718, 253 N.E.3d 107.
Spurgeon v. Mercy Health-Anderson Hosp., L.L.C., 2020-Ohio-3099, 155 N.E.3d 103.
Triplett v. Univ. Hosps. Cleveland Med. Ctr., 2022-Ohio-3553, 197 N.E.3d 1030.
Holland v. Dayton Child.'s Hosp., 2026-Ohio-1678.
Ohio Rev. Code § 2305.25(F): 2 cases
Wall v. Ohio Permanente Med. Grp., Inc., 695 N.E.2d 1233 (Ohio Ct. App. 8th Dist. 1997). “OPMG responds that this court should extend the protection of R.C. 2305.25 to peer review committees of professional physician corporations.”
Sinoff v. Ohio Permanente Med. Grp., Inc., 767 N.E.2d 1251 (Ohio Ct. App. 8th Dist. 2002).
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