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SB 2048

Evidence - As introduced, states that in certain civil actions a licensed nurse practitioner or licensed physician assistant who is properly qualified as an expert witness may testify as to certain medical findings. - Amends TCA Title 24; Title 29, Chapter 26 and Title 50, Chapter 6.

114th Regular Session (2025-2026) Introduced by Todd Gardenhire

The bill allows licensed nurse practitioners and physician assistants to serve as expert witnesses in civil actions (excluding health care liability and workers’ compensation).

Assigned to General Subcommittee of Senate Judiciary Committee
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Bill Summary · SB 2048

Summary of Bill: SB 2048 (Session 114) – Tennessee

Purpose and intent

SB 2048 amends Tennessee law to allow licensed non-physician medical professionals—specifically licensed nurse practitioners (LNPs) and licensed physician assistants (LPAs)—to serve as expert witnesses in civil actions. When properly qualified under the Tennessee Rules of Evidence, these professionals may testify regarding medical findings and related issues as described below. The bill explicitly excludes certain actions from these expanded capabilities (see notable exceptions).

Key provisions

  • New eligible expert testimony (for LNPs and LPAs):

    • Diagnosis of an injury or medical condition.
    • Reasonable and necessary medical care provided.
    • Reasonableness of associated medical charges.
    • Medical causation of an injury, condition, or impairment.
    • Other matters within the scope of expert testimony ordinarily permitted to a physician under the Tennessee Rules of Evidence.

  • Limitations and exclusions:

    • The expanded expert testimony applies only in civil actions other than:
    • Health care liability actions filed under Title 29, Chapter 26.
    • Workers’ compensation claims filed under Title 50, Chapter 6.
    • The bill does not authorize APNs/LPAs to be included on workers’ compensation panels nor to provide testimony in workers’ compensation cases about impairment ratings, disability ratings, or whether an injury is work-related.

  • Qualifications as an expert:

    • The LNP or LPA must be properly qualified as an expert under the Tennessee Rules of Evidence (the standard process already used for physician experts).

  • Effective date:

    • The act becomes law upon the governor’s signature and publication (i.e., it takes effect “upon becoming a law, the public welfare requiring it”).

Affected parties and stakeholders

  • LNPs and LPAs: Potentially more opportunities to provide expert testimony in civil actions (excluding health care liability and workers’ compensation cases) if they meet qualification standards.
  • Civil plaintiffs and defendants: May gain additional witnesses with professional medical expertise to support or challenge medical findings and charges.
  • Hospitals and medical practices: Impact depends on the extent to which they employ or retain LNPs/LPAs as expert witnesses.
  • Healthcare liability and workers’ compensation regimes: Explicitly remain outside the scope of this expanded testimony.

Procedural and timeline aspects

  • Legislative path (as of action history):

    • Introduced and referred to Senate committees in early 2026.
    • Passed first and second readings and introduced to Senate Judiciary Committee, with subsequent calendar placements and deferments noted.
    • The fiscal note indicates a not significant fiscal impact, with costs borne by private parties (no meaningful state/local fiscal impact anticipated).

  • Fiscal impact:

    • No significant state or local government cost anticipated.
    • Any costs associated with opinions rendered by LNPs/LPAs in civil actions would be borne by private parties involved in those actions.

Practical takeaways

  • If enacted, the bill broadens the pool of qualified expert witnesses in civil litigation to include licensed nurse practitioners and licensed physician assistants, subject to standard evidentiary qualifications and the stated exceptions.
  • The change does not affect health care liability lawsuits or workers’ compensation proceedings.
  • The rationale appears to be enhancing access to expert medical testimony while maintaining boundary with existing special-studies (liability and workers’ compensation) and ensuring qualifications align with Tennessee Rules of Evidence.

Note: This summary reflects the text and fiscal note as provided. For enforcement, practitioners should review the finalized statute and any accompanying rules or administrative guidance.

Compiled from official sources — confirm details with the bill’s official record.

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