Michael Callahan, a partner in the firm’s Health Care Practice, was quoted in an article in Credentialing & Peer Review Legal Insider on the theory of apparent agency, which asserts that hospitals can be held liable for negligence in malpractice claims in which the physician is a contracted provider and not an employee of the hospital. Mr. Callahan explains that although the apparent agency theory is prevalent in Illinois, “[contracted physicians] are not employees. They operate in their own departments using their own protocols and procedures, and [the contract group has] their own insurance.” As long as these providers adequately disclose the nature of their independent relationship and separate responsibility to patients, the hospital should not be held liable under this apparent agency theory. (“Are apparent agency disclaimers fair?” July 2009)