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Ramalingam v. Robert Packer Hospital

United States District Court, M.D. Pennsylvania

December 4, 2017

SARAVANAN RAMALINGAM, M.D., Plaintiff.
v.
ROBERT PACKER HOSPITAL, et al., Defendants.

          ORDER

          Matthew W. Brann United States District Judge

         1. On February 5, 2017, Plaintiff Saravanan Ramalingam, M.D., filed a Complaint against Defendants, ECF No. 1, alleging the following facts:

a. Dr. Ramalingam graduated from Stanley Medical College in India in 1998. In 2005, he completed a general surgery residency at that institution, and in 2006, he was certified in general surgery by the National Board of Examiners in New Dehli, India. ECF No. 1 ¶ 8.
b. After further training, Dr. Ramalingam decided he wanted to become a board-certified general surgeon in the United States. To accomplish that goal, however, he needed to complete a general surgery residency at an accredited institution in this country. Id. ¶ 11.
c. Graduate medical education programs, including general surgery residencies, are governed in the United States by the American Board of Surgery (“ABS”) and the Accreditation Council for Graduate Medical Education (“ACGME”). Id.
d. General surgery residencies in the United States normally last five years, but due to his prior experience and training, the ABS gave Dr. Ramalingam permission to enter a general surgery residency program as a 4th year resident - i.e., as a “Post Grad Year Four” (“PGY-4”) resident. Id. ¶ 12.
e. Defendant Robert Packer Hospital/Guthrie Healthcare System Auxiliary (“GHS”) offered Dr. Ramalingam a spot in its General Surgery Residency Program (“Residency Program”), starting in October 2013. Because of his PGY-4 status, he was scheduled to graduate in September 2015. Id. ¶ 13.
f. Defendant Thomas VanderMeer, M.D., was the Director of GHS's Residency Program. Defendant Burt Cagir, M.D., was the program's Assistant Director. ¶¶ 4, 5.
g. The relationship between GHS and Dr. Ramalingam was governed by GHS's “House Officer Agreement, ” which obligated GHS to assign Dr. Ramalingam to the rotations required by ABS. Id. ¶ 14.
h. From October 2013 through January 2014, Dr. Ramalingam performed well in GHS's Residency Program. Id. ¶ 15.
i. ACGME normally requires general surgery residency program participants to perform at least 750 procedures during their residency, but because he would be in GHS's Residency Program for only two years, Dr. Ramalingam asked GHS and Dr. VanderMeer to contact ABS and ACGME to obtain a waiver for the 750-procedure requirement. Dr. VanderMeer and Laura Warner (GHS's residency coordinator) confirmed that they would “promptly” secure those waivers. Subsequently, Dr. VanderMeer and others at GHS advised Dr. Ramalingam that he had no minimum surgery volume requirements. Id. ¶ 16.
j. In February 2014, Dr. VanderMeer told ABS that Dr. Ramalingam was on track to complete the GHS Residency Program, and requested that Dr. Ramalingam's completion date be accelerated to June 2015. ABS granted this request on February 24, 2014. Id. ¶ 17.
k. Dr. Ramalingam successfully completed his PGY-4 requirements and was approved to advance to the PGY-5 class. Correspondingly, GHS and Dr. Ramalingam entered another “House Officer Agreement.” Id. ¶ 18.
l. Based on his newly-established June 2015 graduation date, Dr. Ramalingam began looking for a hepato-pancreato-biliary (“HPB”) fellowship, to begin after completing ...

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