Negligent credentialing is a separate and independent claim from medical negligence, but a negligent credentialing claim cannot proceed without either a simultaneous or prior adjudication of or stipulation to medical negligence.

At issue was whether a hospital’s grant of staff privileges to a physician, otherwise known as credentialing a physician, confers a duty upon the hospital that is separate and independent of the duty the physician owes to the hospital’s patients. If so, the question remained whether a patient’s negligent credentialing claim can proceed in the absence of a prior adjudication or stipulation that the physician was negligent in his care of the patient. The trial court in this case granted the hospital’s motion for summary judgment on the negligent credentialing claim. 

The Ohio Supreme Court affirmed, holding: (1) a negligent credentialing claim cannot proceed without either a simultaneous or prior adjudication of or stipulation that a doctor committed medical malpractice; and (2) because such an adjudication or stipulation was not present in this case, the negligent credentialing claim was properly dismissed.
 

_{Case Law Alerts, 1st Quarter, January 2023 is prepared by Marshall Dennehey to provide information on recent developments of interest to our readers. This publication is not intended to provide legal advice for a specific situation or to create an attorney-client relationship. Copyright © 2032 Marshall Dennehey, all rights reserved. This article may not be reprinted without the express written permission of our firm.}