DHA Quality Assurance Investigation (QAI)
Facing a QAI, summary suspension, or adverse privileging action at a Military Treatment Facility? Your career and your license are on the line. Get experienced defense counsel immediately.
Is Your Medical Career at Risk?
Defense Health Agency (DHA) and military doctors, dentists, nurses, and other healthcare providers working at Military Treatment Facilities (MTFs) operate under two sets of credentialing obligations. First, they hold a state professional license. Second — and equally important — they must maintain clinical privileges with the privileging authority at their MTF. If an adverse privileging action (revocation, denial, suspension, reduction) occurs, the consequences are devastating: removal from patient care, mandatory reporting to the National Practitioner Data Bank (NPDB), notification to your state licensing board, and permanent damage to your career.
When an allegation of clinical incompetence, professional misconduct, or impairment is made against a DHA medical provider(military, civil service, contractor), the Defense Health Agency (DHA) process moves quickly and the rules favor a quality assurance investigation (QAI) over inaction. Understanding what is happening — and getting experienced legal counsel in your corner immediately — is the most important thing you can do.
Attorney Patrick Korody is a former Navy Judge Advocate who has defended military medical providers in QAIs, Peer Review Panels, and adverse privileging actions at MTFs across the globe. He is one of a very small number of attorneys nationwide with substantial experience in this area.
What Is the Defense Health Agency (DHA)?
The Defense Health Agency (DHA) is the joint, integrated Combat Support Agency responsible for directing the management and administration of all Military Treatment Facilities for the Army, Navy, Air Force, and other uniformed services. The DHA's consolidation of military healthcare under a single authority — a process substantially completed around 2019 — brought with it a unified regulatory framework that now governs all military medical providers regardless of branch.
Before the DHA takeover, each military service had its own quality assurance and credentialing regulations. That branch-specific patchwork has been replaced by a single governing policy: Defense Health Agency Procedures Manual 6025.13, Volume 3 (DHA-PM 6025.13, Vol. 3), which establishes the rules for Medical Quality Assurance (MQA), Quality Assurance Investigations, and adverse privileging actions across the entire Military Health System (MHS).
For any DHA medical provider, whether military, civil service, or contractor, understanding the DHA's authority and the procedures under DHA-PM 6025.13, Vol. 3 is no longer optional. It is the framework under which your privileges — and by extension, your ability to practice — can be suspended or revoked.
What Is a DHA Quality Assurance Investigation (QAI)?
A Quality Assurance Investigation (QAI) — sometimes called a QA Investigation — is a formal Medical Quality Assurance process conducted under 10 U.S.C. § 1102 and DHA-PM 6025.13, Vol. 3. It is the primary investigative mechanism through which the DHA evaluates allegations of clinical incompetence, professional misconduct, or impairment against a military medical provider.
Common triggers for a QAI include:
- Missed or delayed diagnoses with adverse patient outcomes
- Surgical complications, wrong-site procedures, or other sentinel events
- Near-miss events flagged through the patient safety reporting system
- Patient complaints alleging substandard care or provider misconduct
- Allegations of impairment — including substance abuse or mental health conditions affecting practice
- Professional misconduct, including boundary violations or inappropriate relationships with patients
- Concerns raised by colleagues, supervisors, or command leadership to include poor documentation standards, failed focused professional practice evaluations (FPPE), and presribing habits
Under DHA-PM 6025.13, the default position is to place the priliged provider in a summary suspension status and pursue a full quality assurance investigation. The DHA has been aggressive in enforcing this posture — which means the threshold for triggering a QAI is low, and the process begins faster than most providers expect.
If you are facing a QAI or adverse privileging action, do not separate from service or resign your position with legal counsel. Adverse action — including NPDB reporting — can be taken against a provider even after separation or resignation, and separation or resigning may negatively impact your case. You should normally remain affiliated while exercising all due process rights through the conclusion of the process.
Summary Suspension: What It Means and What Happens Next
One of the most disorienting aspects of the DHA quality assurance process is that providers frequently learn their privileges are at risk not from a formal notice of specific allegations, but from a summary suspension — an immediate, temporary removal from patient care pending investigation. In many cases, the notice of summary suspension and the notice that a QAI has been initiated arrive in the same document, and the document contains scant details justifying the action.
A summary suspension temporarily relieves the provider of all or a portion of their clinical duties, privileges, and practice while due process procedures are completed. Although a summary suspension does not revoke your state professional license, the practical effect is nearly identical: you may not be permitted to see patients, perform procedures, practice medicine at the MTF, or engage in off duty employment while the suspension is in effect.
Summary suspension carries several immediate consequences that providers and their counsel must address quickly:
Under DHA-PM 6025.13, Vol. 3 — unlike predecessor regulations that used an abeyance process — a summary suspension in effect for more than 30 days triggers mandatory reporting to the National Practitioner Data Bank (NPDB). In our experience, QAIs are rarely completed within the initial 30-day window, making NPDB reporting nearly inevitable in most cases.
When a provider is placed on summary suspension, the MTF Commander is required to withdraw any authorization for the provider to engage in off-duty employment. This can immediately eliminate outside income that many providers rely on.
NPDB reports are visible to state licensing boards, which may independently open their own investigation based on the DHA's actions. A QAI can therefore become the first domino in a multi-front credentialing crisis.
In cases involving alleged impairment or incompetence, the provider may be required to undergo clinical evaluation, supervised practice, or — where substance abuse is alleged — referral to a treatment program.
The moment you receive notice of a summary suspension or QAI, the process has already begun without you. Every day without experienced counsel is a day the investigation moves forward on the government's terms alone.
How the DHA Quality Assurance Investigation Process Works
Under DHA-PM 6025.13, a QAI must follow specific procedural requirements designed to ensure impartiality and preserve the evidentiary foundation for any subsequent adverse action. Understanding the process — and knowing where your rights arise at each stage — is critical to building an effective defense.
The QAI is initiated by the MTF Commander or Credentialing Committee (CC) chairperson. A Quality Assurance Investigating Officer (QAIO) is appointed in writing. The QAIO must qualify as a "peer" — a healthcare provider with similar clinical specialty, privileges, education, and level of training. The QAIO is required to be neutral and free of any personal or professional interest in the outcome. Challenges to the QAIO's qualifications or neutrality are possible and sometimes essential.
The QAIO reviews all relevant materials: patient records, operative reports, physician orders, diagnostic studies, imaging, privileging documents, applicable clinical policies, and any other pertinent clinical data. The investigation must identify the specific allegations, define the scope of review, and evaluate whether the provider's care met the applicable standard under the circumstances — not a retrospective, outcome-driven standard.
The QAIO prepares a written QAI report containing findings of fact, supporting rationale, application of the preponderance-of-the-evidence standard, and a recommendation to the Privileging Authority regarding the provider's privileges. The report forms the evidentiary foundation for all subsequent stages of the adverse action process.
Under DHA-PM 6025.13, Vol. 3, after the QAI report passes legal sufficiency review, the provider must be given a redacted copy of the QAI report and an opportunity to submit a written statement before further credentialing action is taken. The provider typically has 15 days to respond. This is one of the most consequential stages of the entire process — a well-crafted response by experienced counsel can reshape the record before it reaches the Credentials Committee.
The QAI report and the provider's written statement are forwarded to the MTF's Credentials Committee (CC), which reviews the materials and makes a recommendation to the Privileging Authority regarding the provider's clinical privileges.
The Privileging Authority — normally the MTF Director — makes a proposed decision on the provider's continued privileges. If the Privileging Authority is considering an adverse action (revocation, reduction, suspension, or denial), a Peer Review Panel must be convened. The Peer Review Panel is the provider's most formal "day in court" in the DHA process — and where experienced advocacy matters most.
Why Your Response to the QAI Report Is Critical
Of all the stages in the DHA quality assurance process, the provider's written response to the QAI report is where many cases are won or lost — yet it is the stage most providers underestimate or handle without counsel.
The QAI report travels through every subsequent level of review: the Credentials Committee, the Privileging Authority, and — if a Peer Review Panel is convened — the panel itself. Every decision-maker in the process will have the QAI report in front of them. An inadequate, defensive, or medically incorrect response to that report can harden the record against you. A well-crafted response drafted with the assistance of experienced counsel can:
- Identify and challenge factual errors or incomplete analysis in the QAIO's findings
- Contest the QAIO's qualifications or challenge bias or conflicts of interest
- Present evidence of the applicable standard of care with supporting clinical literature
- Contextualize the clinical decisions at issue — addressing patient complexity, available resources, and documentation limitations
- Introduce mitigating factors and positive evidence of the provider's clinical record and qualifications
- Preserve procedural errors for subsequent stages of the process or any appeal
The QAI is not just an internal administrative review. It is the evidentiary record on which adverse privileging actions, NPDB reports, and state licensing board notifications are built. An unguided or poorly crafted provider statement can and will be used against you in every subsequent proceeding.
The NPDB: Why the Stakes Are Higher Than You Think
The National Practitioner Data Bank (NPDB) is a federal information repository that healthcare organizations, hospitals, and state licensing boards use when credentialing providers. An NPDB report does not stay confined to the military health system — it follows you into every civilian healthcare employer you will ever apply to.
Under the predecessor DHA regulations, summary suspensions were not reportable to the NPDB unless they ripened into a formal adverse action. DHA-PM 6025.13 changed this. A summary suspension now triggers mandatory NPDB reporting if it remains in effect for more than 30 days — regardless of the ultimate outcome of the investigation. Because QAIs routinely take longer than 30 days, providers in the DHA system are far more likely to receive an NPDB report than their predecessors were under the old branch-specific rules.
| Potential Consequence | Trigger | Risk Level |
|---|---|---|
| NPDB Report | Summary suspension > 30 days, or adverse privileging action | High |
| State Licensing Board Notification | NPDB report visible to all licensing boards of record | High |
| Loss of Clinical Privileges | Adverse privileging action (revocation, suspension, reduction) | High |
| Off-Duty Employment Prohibition | Summary suspension | High |
| Security Clearance Impact | Adverse actions may trigger security clearance review | Medium |
| Career-Long Credentialing Impact | NPDB report disclosed on every future hospital application | High |
Military Medical Providers We Defend
Korody Law defends all categories of military healthcare providers facing DHA quality assurance investigations, summary suspensions, and adverse privileging actions — regardless of branch or employment status:
Army, Navy, Marine Corps, Air Force, Coast Guard — active duty, reserve, and National Guard components.
Uniformed military officers, civilian government service (GS) employees, and contractor healthcare providers at MTFs.
Physicians, surgeons, dentists, nurses, physician assistants, nurse practitioners, mental health providers, and other credentialed healthcare professionals.
We represent providers at MTFs across the United States and at overseas installations worldwide.
"Mr. Korody is by far one of the most talented and experienced military defense attorneys in the country. Every document, every conversation, every procedure, every single regulation will be scrutinized ten times by Mr. Korody. This man is a consummate professional and is a master of his craft."
Frequently Asked Questions: DHA QAI & Summary Suspension
Governing Regulation: DHA-PM 6025.13
The DHA quality assurance investigation process is governed primarily by Defense Health Agency Procedures Manual 6025.13 (DHA-PM 6025.13), which replaced the previous DoD Instruction 6025.13 and all branch-specific service instructions when the DHA assumed administrative control of all MTFs. DHA-PM 6025.13 is itself authorized by DoD Instruction 6025.13 and 10 U.S.C. § 1102, which provides the statutory framework for the protection and use of military medical quality assurance records.
Key features of DHA-PM 6025.13 that differ from predecessor regulations include:
- Unified policy covering all branches and all MTFs — no more service-specific variations
- Mandatory NPDB reporting for summary suspensions in effect more than 30 days
- Specific QAIO qualification requirements, including the peer definition
- Requirement to provide the provider a redacted QAI report and opportunity to respond before further action
- Peer Review Panel required before any adverse privileging action is finalized
- Preponderance-of-the-evidence standard governs QAI findings
Understanding the specific procedural requirements of DHA-PM 6025.13 — and identifying where the government has failed to follow its own rules — is a core part of effective defense representation in these cases.
Facing a DHA Quality Assurance Investigation? Call Now.
A QAI, summary suspension, or adverse privileging action can end your military medical career and follow you into civilian practice for life. Early, experienced legal representation changes outcomes.
Schedule a Free Consultation (904) 383-7261Disclaimer: This page provides general information about the DHA quality assurance investigation process and is not legal advice for any individual case or situation. Reading this page does not create an attorney-client relationship. Past results do not guarantee any particular outcome in a future case.
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