MEDICAL ERRORS HAVE RECEIVED increased scrutiny in recent years. In 1999, the Institute of Medicine (IOM) report, "To Err is Human," found that medical errors were calculated to be the fifth-leading cause of death in the United States. Such errors are the cause of at least 98,000 deaths per year, according to IOM. But keep in mind that these numbers are estimates; no one knows how many errors go unrecognized or are simply not reported.