Scott R. Simpson, Plaintiff v. Cedar Springs Hospital, Inc., a Delaware Corporation, D/b/a Cedar Springs Behavioral…

Summary

The court held that documents created as part of Cedar Springs Hospital’s quality management program were protected by Colorado’s quality management privilege. Because a quality management program is required for CDPHE licensure, the hospital’s continued licensure established that its program was CDPHE-approved without requiring the trial court to conduct an independent review of regulatory compliance. The court therefore made its rule absolute and remanded for further proceedings.