TBA Law Blog

TBA Law Blog

Supreme Court Rules Hospitals Can Waive QIC Privilege

Posted by: Azya Thornton on May 9, 2025

The Tennessee Supreme Court has ruled that the Quality Improvement Committee (QIC) privilege under state law is waivable. The decision came in a negligence lawsuit brought by Payton Castillo against CHI Memorial Hospital and other health care providers following the death of her husband. After his death, the hospital formed a QIC to evaluate the care he received and later disclosed QIC-protected information to Castillo during a meeting. When she sought to obtain those statements in discovery, the hospital argued they were privileged under the QIC statute, which shields records and statements related to QIC activities from disclosure. Both the trial court and the Court of Appeals found the information was discoverable, and the hospital appealed. The Tennessee Supreme Court held that while the disclosed information fell within the protections of the statute, the hospital waived its privilege by voluntarily sharing the information with Castillo.

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