Practicing doctors don't have the bandwidth to do this except in the most egregious of cases though.

I'm imagining a non-profit organization that solicits any denial by "insurance" companies, determines if it is based on medical reasons, determines if it is medically imprudent (including harm caused by delaying care), and files a mostly pre-prepared complaint to the appropriate medical board. Make it extremely uncomfortable to work for a death panel.

Then if the state boards start really brushing the complaints under the table to protect the death panels, turn it into a direct political issue. Right now there's too much plausible deniability to hide behind.

Sounds like something the "DoNotPay" robo-paperwork-response startup guy Joshua Browder would be interested in implementing: https://twitter.com/donotpay

Who is now being sued for practicing without a law degree.

There was already a baseless suit by a very sue-happy Silicon Valley lawyer -- a clear money grab -- which appears to have been largely dropped after an initial hearing did not seem to go their way. I wouldn't be surprised if this is more of the same.

Besides, I look much more favorably on a startup that is automating the filing of confusing paperwork designed to prevent middle-class folks from holding on to their money, than I am insurance companies that use boiler rooms of hack doctors to deny those same folks medical care.