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The 1999 Institute of Medicine report, To Err is Human, explicitly identified this “wariness” as a significant issue that hampers voluntary reporting and collaborative efforts, including the free exchange of information, to identify medical errors and prevent their repetition. To address this issue, the report recommended that Congress pass “legislation to extend peer review protections to data related to patient safety and quality improvement that are collected and analyzed by health care organizations for internal use or shared with others solely for purposes of improving safety and quality.” To date, however, no comprehensive Federal legislation has been passed. Thus, providers, manufacturers, and health plans must look to a variety of Federal and State laws that may offer protection from disclosure of information pursuant to a discovery request or other judicial or administrative proceedings.