Meanwhile, believing that he would graduate in June 2015, Ramalingam applied to various hepatobiliary and pancreatic (“ HBP”) surgery fellowship programs. But Defendants did not contact ACGME when they contacted ABS they waited until February 2015 to do so. VanderMeer and the Hospital’s residency coordinator assured Ramalingam that they would. So Ramalingam asked VanderMeer to contact ACGME to obtain a waiver for the 750-procedure requirement. Because Ramalingam entered the residency program as a PGY-4, he would have to squeeze requirements designed to be completed over a five-year period into two years. ACGME requires surgical residents to complete 750 procedures over the length of their residencies, which typically last five years. The ABS agreed so long as Ramalingam achieved a requisite score on a qualifying examination and demonstrated the necessary clinical skills for a PGY-4 as attested to by VanderMeer.īut Ramalingam’s early graduation also needed to be approved by ACGME. In early 2014, VanderMeer contacted the ABS and requested that Ramalingam be allowed to graduate in June 2015 rather than October 2015. Such a fellowship, however, would have to commence in July 2015- three months before Ramalingam was scheduled to graduate from the general In early 2014, Defendant Thomas VanderMeer, M.D., the Director of Robert Packer’s Residency Program, advised Ramalingam to apply for a post-residency fellowship. Because of his PGY-4 status, Ramalingam was scheduled to graduate in October 2015. Because of his extensive experience and training, the ABS allowed Ramalingam to enter the Hospital’s five-year residency program as a fourth year resident-i.e., as a “Post Grad Year Four” (“PGY-4” ) resident. American residency programs are subject to requirements promulgated by the American Board of Surgery (“ABS”) and the Accreditation Council for Graduate Medical Education (“ACGME”). Robert Packer Hospital in Sayre, Pennsylvania, offered Ramalingam a place in its general surgery residency program. But to become board-certified in the United States, Ramalingam needed to complete a general surgery residency. He then emigrated to the United States and sought to become board-certified under American standards. Before starting his Residency at the Hospital in October 2013, Ramalingam had graduated from Stanley Medical College in India and been certified in general surgery by India’s Na tional Board of Examiners. BACKGROUND This case stems from Ramalingam’s tim e as a general surgery resident at Robert Packer Hospital. Saravanan Ramalingam, may recover if he proves either of his claims that advanced past summary judgment, while the final motion once again seeks this case’s outright dismissal under the Health Care Quality Improvement Act.īefore moving to the merits of these claims, a brief recap of this case’s background and the applicable legal standard are in order. The Hospital Defendants first three motions try to limit the damages that the plaintiff, Dr. OCTOBefore the Court are four motions in limine filed by the Defendants, Robert Packer Hospital/Guthrie Healthcare System Auxiliary, Robert Packer Hospital, Dr. ROBERT PACKER HOSPITAL/GUTHRIE MEDICAL SYSTEM AUXILIARY, ROBERT PACKER HOSPITAL, THOMAS VANDERMEER, M.D., and BURT CAGIR, M.D.
IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA SARAVANAN RAMALINGAM, M.D.
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