Advanced Practice Providers: Managing Malpractice Risk with an Expanding Workforce

Advanced Practice Providers are essential to modern healthcare delivery. Curi Advisory’s Margaret Curtin shares four key risk areas healthcare leaders should address to strengthen governance and support safe patient care.

Healthcare organizations are facing unprecedented pressure. Workforce shortages, rising patient acuity, financial strain, and increasing demand for access to care are forcing hospitals and health systems to rethink traditional care delivery models.

One of the questions I hear most often from healthcare leaders is how to safely expand the use of Advanced Practice Providers (APPs). And it’s an important question to be asking.

Nurse practitioners (NPs), physician assistants/associates (PAs), certified nurse midwives (CNMs), and certified registered nurse anesthetists (CRNAs) have long been valuable members of the care team, but today their responsibilities, autonomy, and presence across healthcare systems continue to expand at an accelerated pace.

In my view, the question is no longer whether APP utilization will continue to grow—it will. The more nuanced and long-term question is: How do organizations intentionally integrate APPs while ensuring patient safety and effectively managing evolving MPL risk?

Key Takeaways: 

• The continued growth of Advanced Practice Providers (APPs) is reshaping healthcare delivery, creating new medical professional liability (MPL) risks that require proactive governance.
  
  
• Clear supervision, defined roles, and ongoing competency evaluation are essential to safely integrating APPs into increasingly complex care environments.
  
  
• Organizations that treat APP integration as an enterprise risk management strategy—not simply a staffing solution—will be better positioned to reduce risk while supporting high-quality patient care.

What's Driving APP Growth in Healthcare?

What I’m seeing is the increase in APP utilization is not occurring in isolation. It’s being fueled by several simultaneous challenges impacting healthcare organizations nationwide:

• Persistent physician and nursing shortages
  
• Aging patient populations with increasingly complex care needs
• Financial pressures and shrinking hospital operating margins
• Expanding demand for faster, more accessible care
• Growth of retail clinics, urgent care models, and telehealth
• Regulatory changes expanding APP scope of practice

As a result, healthcare organizations are increasingly relying on APPs to fill essential care delivery gaps across inpatient, outpatient, emergency, procedural, and specialty settings.

In many organizations, APPs are no longer functioning solely in supportive roles. They are becoming central providers within care delivery models.

How the MPL Landscape Is Evolving Alongside APP Expansion

Interestingly, current MPL data does not yet show a dramatic increase in claims frequency directly tied to APPs. However, I don’t believe that means organizations should assume their risk exposure is unchanged.

As APP scope of practice expands, the nature of risk is evolving. In my experience, there are several areas that deserve particular attention:

1. Physician Supervision and Accountability
   
   One of the first areas I advise organizations to evaluate is physician supervision of APPs. I've seen how quickly ambiguity around accountability can create unnecessary risk—not only during day-to-day care delivery, but also when organizations are defending clinical decisions after an adverse event.
   
   When I assess APP governance models, these are some of the questions I ask the leadership team:
   
   • Who is ultimately responsible for oversight?
   • What level of physician involvement is expected?
   • How is supervision documented?
   • Are APPs functioning within clearly defined scope boundaries?
   • Do physicians fully understand their supervisory obligations?
   
   As physician shortages worsen, physicians may be supervising larger numbers of APPs while simultaneously managing heavier patient loads themselves. This creates the potential for oversight gaps, inconsistent collaboration, and confusion regarding accountability when adverse events occur.
   
   From an MPL defense perspective, ambiguity in supervision relationships can create significant vulnerability during litigation.
   
   
2. Scope Creep and Increased Patient Complexity
   
   Historically, many APPs managed lower-acuity or more narrowly defined clinical responsibilities. Today, APPs are increasingly caring for medically complex patients in higher-risk settings, including:
   
   • Emergency departments
   • Surgical services
   • Specialty care clinics
   • Inpatient hospitalist programs
   • Critical care support roles
   
   As responsibilities expand, organizations must ensure APP competencies, orientation processes, and ongoing clinical support evolve accordingly.
   
   I encourage leaders to carefully watch for gradual "scope creep." Without intentional governance, responsibilities tend to expand incrementally—often without corresponding updates to training, policies, or supervision models.
   
   
3. Documentation and Communication Gaps That Drive MPL Claims
   
   Many of the risk drivers associated with APP-related claims mirror traditional MPL exposure areas:
   
   • Incomplete documentation
   • Communication breakdowns
   • Delayed escalation
   • Failure to close the loop on test results
   • Inadequate handoffs
   • Ambiguous role delineation
   
   These aren’t new risks, but the complexity of collaborative care models can amplify them. I often advise healthcare organizations build strong structures around:
   
   • Standardized communication pathways
   • Clear escalation criteria
   • Defined documentation expectations
   • Consistent interdisciplinary collaboration
   
   
4. Credentialing, Competency, and Ongoing Evaluation
   
   As APP roles diversify and become more specialized, it’s worth asking whether their current credentialing and competency processes remain sufficient.
   
   Some of the questions I recommend leaders consider include: 
   
   • Are onboarding processes specialty-specific?
   • Are competency assessments aligned with actual practice expectations?
   • Is ongoing peer review meaningful and risk-focused?
   • Are organizations proactively evaluating APP practice patterns and outcomes?
   
   In many organizations, a standardized onboarding process alone may no longer be adequate for increasingly complex APP practice environments.

APP Expansion Requires Mature Enterprise Risk Management (ERM) Thinking

One of the biggest mindset shifts I encourage healthcare leaders to make is viewing APP utilization as more than a workforce issue. From an ERM perspective, APP integration is a strategic organizational risk that touches nearly every aspect of healthcare delivery.

The organizations best positioned for success will move beyond reactive staffing solutions and instead develop intentional governance structures that include:

• Clearly defined supervision models
• Role clarity and accountability
• Monitoring outcome and claims trends
• Aligning policies with evolving regulations
• Conducting proactive risk assessments in high-risk service lines
• Integrating APP risk considerations into broader workforce strategy discussions

APP utilization also intersects with multiple enterprise risk domains simultaneously, including clinical, workforce, operational, financial, regulatory, and reputational risk. Looking at these risks collectively—not in isolation—is what ultimately strengthens organizational resilience.

The Path Forward

It’s clear to me that APPs are now an essential component of modern healthcare delivery. Their continued growth is inevitable given workforce shortages, patient demand, and financial realities across the industry.

The challenge for healthcare organizations is not whether to utilize APPs, but how to do so safely, strategically, and sustainably.

The organizations that will be most successful aren’t simply adding more APPs—they’re intentionally designing care models that promote collaboration, accountability, competency, and patient safety.

As care delivery models continue to evolve, our risk management strategies must evolve alongside them. Because ultimately, the goal isn’t simply expanding access to care—it’s ensuring that care remains safe, coordinated, and defensible.

At Curi Advisory, my ERC Risk Solutions team and I partner with healthcare organizations to evaluate APP integration through an operational, ERM, and MPL risk lens. Whether you’re expanding APP utilization or reassessing existing care models, we can help you strengthen governance, reduce risk, and build a more resilient delivery system. 

Contact me at margaret.curtin@curi.com. Curi Advisory Risk Consulting is here to support you and your organization.

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