Background -

Dr. Steven Valfer is a licensed OB-GYN who was a member of the medical staff at Evanston Northwestern Hospital ("Hospital") until March 16, 2005 when the Hospital's board of directors approved the recommendation to not reappoint him after Dr. Valfer exhausted his fair hearing and appeal rights under the bylaws. The basis of the initial adverse recommendation was a finding by the department chair that there were "multiple surgical cases for which approved indications for the intended procedures appear to be lacking." A previous review of 22 of Dr. Valfer's cases found that at least 50 percent of the surgeries he performed were unnecessary.