On March 27, 2018, the Pennsylvania Supreme Court opined that Pennsylvania’s committee peer review privilege statute does not cover physician performance materials prepared by the defendant independent contractor of the defendant hospital, which staffed and ran the Emergency Department. The case is Reginelli v. Boggs, No. J-25A-2017 (Pa. Sup. Ct. Mar. 27, 2018), involving Monongahela Valley Hospital, Inc. and VPMC Emergency Medicine, Inc. d/b/a Emergency Resource Management, Inc. Many if not most Virginia hospital emergency departments are run by independent contractors.