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OMB Audit Recommendations

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: Partially Implemented, Target Date July 1, 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.

Board staff are working to implement these changes to data collection by July 1, 2025. Data collection will start with Board Actions from the July 10, 2025, Board meeting.



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. Staff plan to determine the key data collection points, perform quality assurance on the data, and develop a framework for analysis in mid-2025 as the work on recommendations 1 and 2 is formalized. 



Recommendation 4: Develop and implement written policies and procedures for analyzing board disciplinary decisions for equity and consistency 

Status: Not Implemented, Target Date July 1, 2026

Summary: Based on the work for other recommendations, a plan will be developed for this recommendation in mid-2025.



Information updated April 10, 2025