A Review of Negligent Credentialing Case Law

Negligent credentialing has become a common means of keeping hospitals in medical malpractice cases even when no hospital employee deviated from the standard of care. Illinois courts first recognized the claim in Frigo v. Silver Cross Hospital, which requires proof that the hospital failed to exercise reasonable care in granting privileges, that the physician committed malpractice, and that the improper credentialing proximately caused injury. Subsequent decisions—including Longnecker, Helfers-Beitz, Blutcher, and Essig—clarify that an underlying malpractice claim is essential and that plaintiffs must present concrete evidence, such as credentialing failures or prior performance issues, rather than conclusory allegations, to sustain the claim.