In hospital peer review committee proceedings, a person hired by a hospital to serve as a hearing officer may be disqualified for financial bias under Business and Professions Code section 809.2(b), on grounds that the officer has an incentive to favor the hospital in order to increase the chances of receiving future appointments.  Under the statute, a hearing officer is disqualified if he might gain a “direct financial benefit” from the outcome of the peer review committee proceeding.  The prospect of being hired by the hospital as a hearing officer in future peer review proceedings can be a “direct financial benefit” sufficient to disqualify the hearing officer, but a mere appearance of bias isn’t enough, instead the financial benefit must create an intolerable risk of actual bias.  Here although the hearing officer earned most of his living as a hearing officer in similar peer review committee proceedings, the hospital involved in this one required a three-year wait between proceedings with the same hearing officer, which was a long enough wait to avoid intolerable risk of actual bias.  And this was true even though the hearing officer might be employed meanwhile by other hospitals owned by the same company because by law the decision to appoint a hearing officer is for the hospital’s medical committee to make, not its corporate management.