In April 2023, the Oregon Secretary of State began an audit to review the consistency with which the Oregon Medical Board handles its disciplinary process. The results were released in a January 2024 report,
To Protect Patients and Maintain Public Trust, the Oregon Medical Board Should Further its Efforts to Address the Risk of Inequitable Disciplinary Decisions. The OMB quickly began work on the audit's recommendations.
Recommendation 1: Implement
sanctioning guidelines and/or a sanction matrix to help reduce the risk of
inconsistent and inequitable case decisions.
Status: Implemented April 3, 2025
Summary: OMB staff reviewed investigative guidance from fellow state boards and organizations. Additionally, the Board hired an intern studying for a masters in biostatistics to conduct a five-year retrospective review of the OMB's investigative case outcomes. Through these efforts, Board staff drafted an initial guidelines document.
In August 2024, the Board convened a workgroup of licensee-representing attorneys, advocates for patient safety, professional associations, members of the public, and OMB members. The workgroup held public meetings to refine the guidelines. The Workgroup's recommendations were reviewed by the OMB's Administrative Affairs Committee, as well as all members of the Board, throughout the process.
Workgroup meetings:OMB Disciplinary Guidelines adopted by the OMB on April 3, 2025.Recommendation 2: Add the ability to categorize cases by primary
or most serious complaint type, or another effective categorization system, to
its forthcoming new data system.
Status: Implemented July 1, 2025. Staff collected data on outcomes during the Board meeting on July 10, 2025.
Summary: Upon review, the OMB’s current database captures
“complaint category” when a complaint is received. This is not adequate for
analyzing the equity and consistency of disciplinary outcomes. Staff reworked
an existing statutory violation data field to meet this need. The data field
will be populated by the Executive Director in consultation with the Assistant
Attorney General and Investigations Manager during the process for issuing
disciplinary actions. The data field will allow the agency to designate a primary
and secondary statutory violation.
Recommendation 3: Use
complaint data to conduct regular, systematic reviews of past cases to help
monitor for and ensure equity and consistency
Status: Not Implemented. Target Date July 1, 2026
Summary: A full year’s data will be necessary for meaningful analysis. See plan summary below.
Recommendation 4: Develop
and implement written policies and procedures for analyzing board disciplinary
decisions for equity and consistency
Status: Not Implemented. Target Date January
1, 2026
Summary: Following implementation of the OMB disciplinary guidelines on April 3, 2025, Board staff began collecting data on all disciplinary and corrective action decisions starting with those decisions made at the board meeting on July 10, 2025.
The plan is to compare disciplinary and corrective action decisions with similar statutory violations to see if outcomes are consistent and equitable, while accounting for unique circumstances and mitigating or aggravating factors. The analysis will also develop recommendations to ensure future disciplinary and corrective action decisions are equitable and consistent. As Board staff develop this process to collect and review data to carry out the analysis and review for Recommendation #3, written policies and procedures will be created and updated as needed.
Information updated September 2025