Kaiser Peer Review Process: What Every Kaiser Doctor Needs to Know About P2 Scores and Disciplinary Action
Facing Peer Review at Kaiser Permanente? You’re Not Alone.
If you’re a Kaiser physician who has recently received a P2 score, been placed on a Practice Improvement Plan (PIP), or are under Focused Professional Practice Evaluation (FPPE), you’re likely feeling significant stress and uncertainty. You are often treated as if this is collaborative and team based - We are not looking to hurt you - we want to work together to improve.
But the team approach has faded from days of Kaiser past. The current Kaiser system can quickly escalate from the team veneer to full blown discipline. We have seen lifetime career Kaiser doctors scrutinized by committees advised by physicians with relatively little experience. Agenda's other than medical care guide P ratings and the Kaiser doctor is often bewildered by the sudden shift to an adversarial posture by Kaiser and its medical committees.
The Kaiser Permanente physician disciplinary system is complex, peer-driven, and can quickly escalate from “remediation” to formal discipline — including potential termination and a report to the Medical Board of California. Understanding the process is critical to protecting your career.
How the Kaiser Physician Disciplinary System Works
Kaiser Permanente (through The Permanente Medical Groups — TPMG in Northern California and SCPMG in Southern California) uses a structured, tiered peer review process that is governed by the Medical Group’s Partnership Agreement and Medical Staff Bylaws.
Here’s how it typically unfolds:
1. The Quality Trigger: Potential Quality Issue (PQI)
Most cases begin with a Potential Quality Issue flagged by:
- A patient complaint
- Unexpected complication or outcome
- Colleague referral
- Data showing higher-than-average complication rates
2. The P2 Score – The Critical Turning Point
Kaiser uses a P-Score system:
- P0 = Care meets standard
- P1 = Minor opportunity for improvement
- P2 = Significant opportunity for improvement or care deemed inappropriate
A P2 score is the main gateway into the formal disciplinary track. Once issued, you usually have 60 days to enter a Practice Improvement Plan (PIP). While often presented as “educational,” a P2 is frequently the first step toward more serious action.
Important: Many Kaiser doctors underestimate the long-term impact of a P2. Multiple P2s or failure to successfully complete a PIP can lead to loss of privileges, termination, and an 805 report to the Medical Board.
3. OPPE and FPPE Monitoring
Kaiser follows Joint Commission standards:
- OPPE (Ongoing Professional Practice Evaluation) – Routine monitoring for all physicians
- FPPE (Focused Professional Practice Evaluation) – Intense, targeted monitoring triggered by a P2 or other concerns
Failing an FPPE often shifts the case from remediation to formal disciplinary proceedings.
4. Investigatory Review Committee (IRC) and Corrective Action
If concerns persist, your case may go to an Investigatory Review Committee. This can result in:
- Letter of Admonition
- Additional training
- Monitoring by proctors
- Probation with restrictions
- Suspension
- Termination of employment/partnership
A danger many Kaiser doctors confront follows the successful completion of additional training or proctoring. Months or even years later a new P2 arises only this time the committee uses the successful completions against the doctor. They reason that the previous matter was the doctors "chance" and since the doctor has a pattern of failure more punitive measures are now the only options on the table. In other words, a "friendly" first encounter willl be used against you in the future. We had a case involving a Kaiser surgeon where he did not contest the P2 because he was told that everyone understood it was "borderline". A very brief retraining on the use of a particular surgical tool was all he needed. Two years later another situation arose and one of the prime allegations against him was that the prior P2 was serious and he failed to learn from that incident.
The Kaiser By-Laws describe the rules for peer review hearings, administrative suspension and other disciplinary matters. They vary slightly location by location. Review your Kaiser By-Laws Here.
You should also review the Kaiser Code of Conduct which defines how you have to act with respect to other physicians, members of medical staff and patients. Read Kaiser Principles of Responsibility Here
5. 805 Reporting to the Medical Board of California
Certain actions — especially restrictions lasting more than 30 days or termination — trigger a mandatory Section 805 report to the Medical Board. This can have devastating effects on your ability to work at other hospitals or health systems.
Kaiser's internal system is governed by it's by-laws which in Kaiser's own terms which outline the rules for clinical quality evaluations and grievance procedures. However these by-laws must track the same California law that establishes peer review guidelines for all hospitals. (Learn More about the Standard Peer Review Rules) If Kaiser's rules give greater protections that is good but they cannot fall below the state mandated defaults in terms of fairness and due process.
Reporting likewise must follow state law rules set forth in Business & Professions Code section 805. Kaiser's internal policies are useful to know because they clearly define what is reportable. A P2 for example will not be reported but there is still the question as to what is an investigation under Kaiser rules such that a resignation while under investigation may be reportable to the state and NPDB. (See our blog on Resigning Under Investigation)
Why Kaiser Doctors Need Experienced Legal Representation
Kaiser’s peer review process is designed to appear collaborative, but the reality is that the system can move quickly against physicians. Peer review committees sometimes include physicians from different specialties or with limited experience reviewing your specific area of practice. Political dynamics and departmental pressures can also influence outcomes.
In our experience with Northern California Kaiser there is a tendency toward a self congratulatory focus on patient perspectives when peer review is initiated. Credibility issues are often decided in favor of patients and in a protective manner to remove Kaiser from direct criticism. We have had cases in both Northern and Southern California where Kaiser compromised with a doctor on a non-reportable finding but years later - that same doctor was sanctioned and reported because a new complaint was found to be similar to the old complaint that had seemingly vanished. For this reason we advise our Kaiser doctors to be very careful before accepting a disciplinary finding and to be equally careful in the wording of such a finding if it is every entered against the doctor.
Our office handles peer review issues daily - this experience allows us to see your situation in a deeper and broader perspective than your view as the individual subject to the inquiry. It is good judgment on your part to have our physician lawyers in your corner either directly or on the sidelines giving you advice.
Early intervention is essential. The decisions you make in the first 30–60 days after receiving a P2 or PIP can determine whether your case stays internal or escalates to the Medical Board.
If you are a Kaiser Permanente physician currently facing peer review, a P2 score, FPPE, or any disciplinary action, do not navigate this alone.
At the Horowitz law firm we have decades of combined experience defending physicians in Kaiser peer review matters, Medical Board investigations, and fair hearings. Attorney Daniel Horowitz and physician-attorney Dr. Mark Ravis understand both the medical and legal sides of these battles.
Protect your license and your career. Call us today for a confidential consultation: (925) 291-5388
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