Getting a letter from the state medical board when it's not time for license renewal is enough to make any physician's heart skip a beat. Most of the time, these envelopes contain something routine — newsletters, CME updates, rule changes — but that doesn't stop the surge of anxiety that comes with seeing the medical board's seal on the envelope. For many physicians, there's always a lurking fear: What if a patient has filed a complaint?
I've known several physicians who have received such letters. Some are colleagues I know well; others I've heard about through peers, and occasionally even through patients who have mentioned filing complaints about their "other doctors."
One of the colleagues was investigated after a patient complained about their "refusal" to check morning cortisol levels for Cushing's disease. As it turned out, the patient was never refused the Cushing's disease workup, but was informed that the morning cortisol was not the appropriate test to diagnose cortisol excess and was instead offered a set of other tests indicated per guidelines. The patient apparently found those to be inconvenient and insisted on a morning cortisol check. After some back and forth over the patient portal, an offer was made for a televisit to further clarify, but the patient proceeded to file a complaint.
Another physician in hospital medicine admitted a patient with nausea and vomiting of unknown cause for many years. Extensive workup had not identified any singular etiology. Inpatient management improved the symptoms, and the patient was planned to be discharged with continued outpatient management. The patient filed a complaint on the grounds that the discharge from the hospital was premature and put the patient's safety at risk. The medical board initiated a review, but the complaint was dismissed following the physician's initial response.
The list of such examples goes on and on.
Of course, there are rightful, well-deserving complaints involving compromise of patients' well-being that require medical boards' full might and resources to investigate. Handling of patients' complaints is indeed an essential regulatory function of the state medical boards. It serves a crucial role to ensure the practice of medicine is in the best public interest. At first glance, the examples mentioned appear reasonable, or at least understandable. They seem to arise from either patients' limited insight into disease processes or perhaps complex health system workings beyond physicians' control.
However, out of the three variables in this equation, that is, the medical boards, patients, and physicians, there is an undue burden on physicians in this process.
I practice in the state of Texas. According to the official statistics, the Texas Medical Board received 9,184 patient complaints in 2024, translating into around 25 complaints per day, including weekends and holidays. However, 40% of these complaints are dismissed after the physicians' initial response. But even a complaint that gets dismissed requires significant time, energy, and financial resources to address on the part of physicians.
To put it more objectively, if half of those complaints (around 4,592) triggered a formal review and 40% of those — roughly 1,837 — were dismissed based on the physician's first response, and let's assume if average response time was 10 hours to prepare, that's more than 18,370 hours or full 765 calendar days worth of physicians' time. If the average cost of legal and administrative overhead per case is $1,500 (extrapolated from the above examples), then it's estimated that over $2.75 million was spent just to dismiss complaints that did not lead to further action. This doesn't begin to capture the emotional toll: the stress of responding to an inquiry, the fear of reputational damage, the anxiety that lingers during the review process.
This burden must contribute to physician burnout, promote the practice of defensive medicine, and overall increase the cost of health care. The system is weighted toward a model that often feels like "guilty until proven innocent."
So the question is, can and should state medical boards employ better strategies to triage complaints while maintaining impartiality? Can the three variables in this equation be rebalanced?
Many medical boards utilize attorney-investigators and physician-investigators to review administrative and clinical complaints, respectively. It seems reasonable to ask whether a complaint should be reviewed in greater depth for merit by more than just internal investigators before a physician is pulled into the process.
One possible solution would be to expand the peer review process. When a complaint is filed, and if the board's internal investigators deem it appropriate, they request the patient signs a Release of Information (ROI). The board could then obtain the medical records and have them de-identified and reviewed by peers in the same specialty, preferably from outside the state to avoid conflicts of interest. If these reviewers unanimously determine that there is no violation or deviation from the standard of care, the matter could be closed without further action. If there is disagreement, formal review could be initiated, and the physician could be contacted to respond.
This approach maintains fairness and objectivity while protecting physicians from unnecessary stress and expense. It also respects patient confidentiality, with proper de-identification and documentation standards. Of course, peer reviewers would need to be compensated for their time. The burden should not be shifted from one group of physicians to another without support.
Another option worth exploring is the use of AI models in addition to or as alternatives to the peer review process. I realize, utilizing such tools in this area presents ethical conundrums, is somewhat controversial, and has never been explored to the best of my knowledge. But it might be worth considering. If anonymized clinical records based on a complaint were reviewed by AI models trained on evidence-based guidelines, the system could help determine whether care was aligned with best practices. This would not be appropriate for every case, especially those involving administrative delays or interpersonal issues, but it could be valuable for screening clinical complaints.
The practice of medicine is nuanced. Patients' frustrations and complaints arise for a multitude of reasons — some unreservedly credible, necessitating the identification of high-risk practices and physicians who need to be held accountable for deviating from the standard of care, either clinical or administrative, that might or already have led to patient harm. But others are shaped by confusion or unmet expectations. The role of the medical board in safeguarding public health is essential. And when violations occur, boards must act swiftly and decisively.
But the current system places too heavy a burden on physicians. The presumption, all too often, feels like guilt rather than impartial inquiry. That needs to change. Because when physicians are forced to constantly defend themselves from "unvetted" complaints, everyone suffers — physicians, patients, and the system as a whole.
What is your experience with patient complaints and subsequent burdens on your time? Share in the comments.
Dr. Ameer Khowaja is an endocrinologist based in San Antonio, TX. In addition to his clinical practice, he enjoys participating in population research, teaching internal medicine residents, community volunteer work, reading, writing, and spending time with his family. Dr. Khowaja was a 2024–2025 Doximity Op-Med Fellow.
Image by dickcraft / Getty Images
