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Hospitals must file a National Practitioner Data Bank report on any physician's surrender of privileges if an investigation is underway. This has always been a Data Bank reporting requirement, intended to discourage plea bargains which allowed physicians to avoid being reported if they agreed to waive hearing rights.
In 2015 the NPDB Guidebook published expanded descriptions of "investigation" and "surrender" stretch what is to be considered a reportable surrender of privileges. In October 2018, a new Guidebook modifies these and other reporting descriptions.
OPPE and FPPE and other peer review can be affected, as are physicians ability to make practice decisions without inadvertently tripping Data Bank reporting triggers. Medical staff bylaws and policies need to be reworked under the newest Data Bank Guidebook."