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Human fallibility has long necessitated quality control measures in most professions.  In the sensitized health care context, such measures bear heavy scrutiny and conjure up zealous advocacy.  Medical error seized a national spotlight in the 1970s and 1980s as medical malpractice claims increased exponentially, grabbing the attention of health care professionals and lawmakers, and increasing efforts to improve the quality of health care along with the legislation and regulation surrounding medical treatment.  Internally conducted reporting mechanisms within the medical community emerged as a common means of improving service quality and reducing medical error.  Hospitals and other health care providers increasingly utilized peer review reporting as a method of reducing medical error, while state legislatures almost unanimously enacted statutory protections strengthening the efficacy of peer review committees. . . .