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Key Findings

In Pictures

Three charts summarize this paper's core reporting-volume and rate contrasts; full context and the complete comparator set appear in the sections that follow. Figures 1 and 2 reflect the corrected separation of Government Administrative actions (reptype 604) from DEA actions (reptypes 601/602); Figure 3 is unaffected by this report-type correction. Figures 2 and 3 continue to use a BLS-based denominator for dentistry rather than CMS, disclosed in each figure's caption and explained in §2.4 and §5.

Figure 1. 2010–2025 NPDB Reporting Volume by Type and License Category. Aggregate report activity varies widely, in both report type and volume, across license categories. Chiropractors (DC) and Physical Therapists (PT) show modest aggregate report volumes relative to larger-workforce fields such as physicians, nurses, and nursing assistants. In this revision, Government Administrative actions (reptype 604) and DEA actions (reptypes 601/602) are classified and displayed separately. Source: corrected NPDB public-use extract, 2010–2025. Visualization was human generated.

Figure 2. 2023–2025 NPDB Reports per 10,000 Denominator Units by Type and License Category. This normalizes NPDB report volumes by the number of providers; the denominator is CMS-enrolled provider-years for every field except Dentist*, which uses BLS-employed dentists — CMS's Medicare-enrollment denominator substantially undercounts dentistry given limited Medicare dental coverage (§2.4, §5), and BLS's broad Dentists occupation (SOC 29-1020, encompassing general dentistry and dental specialties, matching NPDB's own field-of-licensure definition) is a materially better match. The 2025 BLS employment estimate was multiplied by three to approximate a 2023–2025 provider-year quantity consistent with the other bars, assuming stable dentist employment over the period (§2.4). Government Administrative actions (reptype 604) and DEA actions (601/602) are classified as separate series. Total rates and field ordering are unchanged by this correction. *Dentist denominator: BLS, 2025 estimate × 3; all other fields: CMS, pooled 2023–2025. Source: corrected NPDB public-use extract. Visualization was human generated.

Figure 3. 2025 NPDB Malpractice Reporting Rate, Volume, and Payment Amount Per Claim. Three distinct measures appear together: the y-axis is the malpractice-report rate per 10,000 denominator units, the x-axis is the mean paid amount per claim, and bubble size is the raw number of malpractice payment reports (not a rate). Dentist (BLS) uses BLS 2025 employment as its denominator rather than CMS, for the same reason as Figure 2 (§2.4); this is a single-year 2025 figure, so no tripling approximation is needed here. On the corrected denominator, podiatrists have the highest malpractice-report rate (94.6 per 10,000), just above dentists (80.3). MD/DO physicians have by far the largest raw volume of malpractice payment reports (the largest bubble), which is far more moderate on a per-provider basis once adjusted for the number of providers. MD/DO physician malpractice award amount per claim is relatively high. Chiropractors have a moderate adjusted malpractice-report rate, raw report volume, and award amount relative to the full comparator set. Source: NPDB public use file, 2010–2025. Visualization was human generated.

Arete's Take

Table 1. At a Glance

All figures were independently recomputed from the corrected NPDB v2.2 aggregate extract and the supplied CMS, NPPES, and BLS denominator extracts. CMS, NPPES, and BLS denominators represent different populations and should not be treated as interchangeable. “Rank X/15” means DC's or PT's position when all 15 fields available under that specific denominator are sorted from highest to lowest report rate (1st = highest rate); each denominator's 15-field set is defined and compared in §2.4, and the CMS/NPPES/BLS sets are not identical to one another, so a rank under one denominator is not directly comparable to a rank under another (§2.4, Table 5).

Abstract

Using the National Practitioner Data Bank (NPDB) Public Use Data File through March 31, 2026, this descriptive study examines national report volume, report-type composition, and selected severity measures across healthcare fields of licensure. The principal historical period is processing years 2010–2025; partial-year 2026 is excluded. Recent rates use pooled 2023–2025 numerator reports divided by Centers for Medicare & Medicaid Services (CMS) Medicare provider-enrollment counts or active National Plan and Provider Enumeration System (NPPES) provider-years. A separate 2025 sensitivity analysis uses U.S. Bureau of Labor Statistics (BLS) Occupational Employment and Wage Statistics (OEWS) employment estimates. Organizational licnfeld codes (≥ 1000) are excluded from the profession-level analysis.

Across individual-practitioner fields, 1,105,678 reports were processed during 2010–2025. Licensure actions accounted for 69.5%, malpractice payment reports 17.0%, exclusions 8.4%, government administrative actions 2.4%, clinical-privileges actions 1.9%, DEA actions 0.7%, and professional-society actions 0.1%. Annual processed volume declined from 89,973 in 2010 to 64,508 in 2025, largely because licensure-action reports declined. Processing-year and event-year patterns differed materially: from 2010 to 2019, processed adverse-action reports fell 23.4%, while adverse actions grouped by event year increased 4.3%, underscoring the importance of reporting lag and backlog effects.

Chiropractors generated 14,585 reports during 2010–2025, compared with 7,023 for physical therapists. During 2023–2025, total report rates were 133.4 per 10,000 CMS provider-years for DCs and 37.8 for PTs; NPPES rates were 67.5 and 18.8. The corresponding DC/PT ratios were 3.53× and 3.59×. Malpractice-rate ratios were 6.44× and 6.56×. Chiropractors ranked fourth among 15 fields under both CMS and NPPES and second under a corrected 2025 BLS view (§2.4); physical therapists ranked 11th, 12th, and 12th. DC reports also had a broader category mix and higher mean coded malpractice payments and specified action lengths than PT reports. These data characterize reporting patterns, not exposure-adjusted clinical risk, unique-practitioner incidence, or causal effects of professional practice.

Independent recomputation of every headline figure in this abstract, directly from the supplied aggregate extract and denominator workbook, reproduced the source manuscript's stated values without material discrepancy; see the internal AI Assistance and Reproducibility Record maintained under the Arete Research Library Governance Framework for the full reconciliation detail.

Background

The National Practitioner Data Bank was established by Title IV of the Health Care Quality Improvement Act of 1986 (Public Law 99-660) and began collecting reports on September 1, 1990. Congress created it to address a specific, documented problem: a practitioner disciplined or sued for malpractice in one state could relocate and begin practicing in another state where hospitals, health plans, and licensing boards had no practical way to discover that history, because the relevant records were scattered across state and local systems that did not communicate with one another. The NPDB's stated purpose is to improve the quality of health care by giving hospitals, state licensing boards, health plans, and other authorized entities a single federal source to check before granting a license, credentialing decision, or clinical privileges — not to publicly rank or rate practitioners or professions. It is administered by the Health Resources and Services Administration (HRSA) and is confidential: individual reports are not searchable by the public, and hospitals are required to query it when practitioners apply for privileges and again at defined intervals thereafter.

The NPDB's scope has expanded twice since 1986. As originally enacted, it centered on malpractice payments and adverse licensure, clinical-privileges, and professional-society actions, with physicians and dentists as the primary practitioner groups covered. The Medicare and Medicaid Patient and Program Protection Act of 1987 (codified at Section 1921 of the Social Security Act) broadened mandatory reporting of state licensing-board sanctions to all licensed health care practitioners and entities, not physicians and dentists alone; a 2010 final rule from the U.S. Department of Health and Human Services (HHS) implemented that broader collection in practice. In May 2013, a separate federal repository, the Healthcare Integrity and Protection Data Bank (HIPDB, created under the Health Insurance Portability and Accountability Act (HIPAA) in 1996 to track health care fraud and abuse), was merged into the NPDB, consolidating both data streams into the single system this paper's numerator draws from — the structural break noted in Key Limitations. The de-identified, aggregate Public Use Data File used throughout this paper is a separate product built for research and policy analysis; it is not the confidential, queryable system hospitals and licensing boards use for individual credentialing decisions, and it carries none of the individually identifying information that system contains.

This paper's purpose, stated on the cover, is to characterize NPDB reporting patterns across fields of licensure and compare chiropractic with physical therapy and other healthcare professions — both in raw volume and, more importantly, adjusted for the size of each field's workforce. That comparison matters because raw NPDB volume is sometimes cited in professional, regulatory, and public discourse without a workforce denominator attached, which can make a large field look disproportionately reported-on (or a small field look disproportionately safe) simply as an artifact of its size, independent of any difference in underlying practice. Sections 3–4 present raw volume and category mix; Section 5 introduces the denominator-adjusted comparison that is this paper's central analytic contribution; Sections 6–7 focus that comparison on chiropractic and physical therapy specifically; and Section 8 states directly what this comparison does and does not support — principally, that NPDB reporting position is a regulatory and administrative measure, not a validated measure of comparative clinical safety (see also Key Limitations). This paper uses a number of federal-agency and profession abbreviations throughout (NPDB, CMS, NPPES, BLS, and others); each is spelled out at first use, and the Glossary (immediately after References) collects all of them in one place for reference while reading.

Methods

2.1 Data Sources and Study Population

The numerator source was the corrected NPDB v2.2 aggregate extract, derived from the NPDB Public Use Data File using the revised SQL supplied for this analysis. The source public-use file contains 1,911,185 reports from September 1990 through March 31, 2026 (1,378,478 adverse-action reports and 532,707 malpractice-payment reports — both figures independently confirmed by summation of the supplied file). The main analysis includes individual-practitioner licnfeld codes below 1000 and processing years 2010–2025. (licnfeld, lowercase as NPDB's own data dictionary defines it, is the field-of-licensure code assigned to each report; it is not a typographical inconsistency in this paper — see the Glossary for a full list of the licnfeld codes used here.) Organizational and facility codes beginning at 1301, records with missing licnfeld, and partial-year 2026 are excluded from profession-level results. The supplied extract contains one aggregate row per combination of processing year, event year, effective year, practitioner state, license state, licnfeld, and record category; national counts are obtained by summing decomposed count fields. Restricting to processing years 2010–2025 and licnfeld below 1000 yields 1,105,678 individual-practitioner reports, confirmed independently from the corrected extract.

2.2 Report Categories and Fields of Licensure

Report categories follow the corrected v2.2 NPDB extraction methodology: malpractice payments; licensure actions; clinical-privileges actions; professional-society actions; U.S. Drug Enforcement Administration (DEA) actions; government administrative actions; exclusions or debarments; and accreditation actions. DEA actions are reptypes 601 and 602; reptype 604 is Government Administrative Action (Individuals), covering actions concerning participation in federal or state health care programs. Earlier extraction logic had grouped reptype 604 with DEA. Correcting that error reclassifies 26,357 reports within the 2010–2025 individual-practitioner cohort from DEA to government administrative actions; total report counts, total-report rates, denominator rankings, and malpractice-specific analyses are unchanged. The main comparison emphasizes licnfelds with externally available denominator data, including physicians, dentists, pharmacists, nurses, allied-health professions, chiropractors, and physical therapists. Physicians coded as MD and DO are combined for denominator-adjusted results because the CMS physician denominator rolls both into one field; raw volume tables report MD and DO separately.

2.3 Processing Year, Event Year, and Reporting Lag

Processing year is the year a report was first processed into the NPDB. Event year is the year of the underlying adverse action or malpractice act or omission. The methods extract indicates that approximately 75% of adverse actions are processed in the event year, while malpractice payments most commonly lag the underlying event by three to four years. Main annual tables therefore use processing year to describe what the NPDB received. Event-year comparisons are used only to test whether apparent processing-year changes reflect underlying event patterns; recent malpractice event-year data are not interpreted because they are structurally incomplete.

2.4 Denominators and Rate Construction

The denominator workbook supplies four SQL-based approaches. CMS's Provider Enrollment, Chain, and Ownership System (PECOS) counts Medicare-enrolled providers by year and state for 2023–2026. NPPES provides active individual National Provider Identifier (NPI) counts for 2018–2026. BLS's OEWS program provides 2025 state employment estimates, including occupations that do not bill Medicare directly. CMS Payroll-Based Journal data are described in the methods as a nursing-home staffing source, but the supplied workbook contains 2021 only; PBJ is therefore not used in headline results. National CMS and NPPES rates pool 2023–2025 reports and provider counts as provider-years. BLS rates use 2025 reports divided by 2025 employment. All rates are reports per 10,000 denominator units.

CMS and NPPES use the same 15-field comparator set (Table 4, Appendix A3a). The 15-field BLS sensitivity set (Appendix A3b) differs: it substitutes occupations with available BLS employment estimates — Registered Nurse, LPN/LVN, Pharmacy Technician, Nurse Aide/CNA, and Respiratory Therapist — for five fields the CMS/NPPES set includes but BLS does not track separately in this workbook (Physician, Social Worker, Psychologist, Nurse Anesthetist, Audiologist). Rank positions are therefore comparable within a denominator source (e.g., chiropractic's CMS rank against dentistry's CMS rank) but not directly across sources (e.g., chiropractic's CMS rank of 4th is not being compared to the same 15-field population as its BLS rank of 2nd). Every “X of 15” statement in this paper refers to that statement's own denominator-specific comparator set, stated here once rather than re-qualified at each occurrence.

For dentistry specifically, Table 4 and Appendix A2's formal 15-field CMS ranking retain the CMS denominator for every field, including dentists, for internal consistency across that comparison. In Pictures Figures 2 and 3 instead substitute BLS employment for dentists' denominator, because CMS's Medicare-enrollment count is nonrepresentative of dentistry for a specific, documented reason: Medicare provides essentially no routine dental benefit, so the large majority of practicing dentists have no billing relationship with Medicare and never enroll in PECOS.

NPDB–BLS Crosswalk for Dentistry

NPDB licnfeld 30 is the broad field-of-licensure category “Dentist,” not “General Dentist.” NPDB separately maintains dental specialty codes (D1 General Dentistry, D2 Dental Public Health, D3 Endodontics, D4 Oral and Maxillofacial Surgery, D5 Oral and Maxillofacial Pathology, D6 Orthodontics and Dentofacial Orthopedics, D7 Pediatric Dentistry, D8 Periodontics, D9 Prosthodontics, DA Oral and Maxillofacial Radiology, DC Dental Anesthesiology), and its documentation and sample reports confirm that specialists — an orthodontist or oral/maxillofacial radiologist, for example — are still coded under field of licensure 30, with specialty captured separately. The Public Use File, however, does not carry that specialty field: NPDB states specialty is not required and, for malpractice payment reports specifically, is not collected at all. This paper's licnfeld-30 numerator therefore already spans general dentistry and dental specialties combined — it was never a general-dentist-only figure — and the matching BLS denominator needs to span the same scope.

The BLS Standard Occupational Classification splits dentistry into five detailed occupations: 29-1021 (Dentists, General), 29-1022 (Oral and Maxillofacial Surgeons), 29-1023 (Orthodontists), 29-1024 (Prosthodontists), and 29-1029 (Dentists, All Other Specialists), rolling up to the broad occupation 29-1020 (Dentists). This paper's denominator uses the broad 29-1020 national estimate — 141,610 in the May 2025 OEWS national release — rather than summing a subset of the detailed codes, because licnfeld 30's scope (general dentistry plus specialties) matches the broad occupation, not any single detailed code within it. An earlier version of this analysis constructed the BLS dentistry denominator from only 29-1021 and 29-1029, omitting 29-1022, 29-1023, and 29-1024 (oral/maxillofacial surgeons, orthodontists, and prosthodontists) and understating the denominator by roughly 12% (125,950 versus the correct 141,610); that omission is corrected throughout this version. One residual imprecision remains and is disclosed rather than resolved: some oral and maxillofacial surgeons hold dual DDS/DMD and MD credentials, and the Public Use File does not indicate whether a given dual-licensed OMS's NPDB report was associated with their dental or medical license, so licnfeld 30 may capture some but not all practicing OMS — see Key Limitations.

Cross-referencing against ADA Health Policy Institute's reported 202,485 professionally active U.S. dentists (2024), CMS's 2025 count (60,291) is equivalent to about 30% of the ADA HPI professionally active dentist estimate, while BLS's corrected 2025 estimate (141,610) is equivalent to about 70% — BLS OEWS explicitly excludes the self-employed, and dentistry has a substantial solo/small-practice ownership share, so BLS likely remains an undercount too, but a far less severe one than CMS's. Figure 2 pools three years of other fields' CMS provider-years for comparability; because BLS OEWS is only available as a single 2025 estimate in the supplied workbook, that estimate was multiplied by three to approximate a 2023–2025 provider-year quantity, assuming stable dentist employment over the period (a reasonable approximation given the profession's documented sub-1%-annual growth, but an approximation, not a measurement). This is not applied to any other field. Figure 3 uses 2025-only data throughout, so no such approximation is needed there.

Analytic rule for this substitution: BLS is substituted for CMS only where a specific, externally verifiable mechanism explains why CMS is nonrepresentative for that profession — not merely where the two sources disagree. For dentistry, that mechanism is documented and external to this paper's own data: Medicare covers essentially no routine dental care, so the large majority of practicing dentists have no reason to enroll in PECOS, and ADA Health Policy Institute's independently published dentist-workforce count corroborates that CMS captures only a small share of the true population (§2.4). Appendix A6 shows this is not the only field where CMS and BLS disagree substantially — Physical Therapist's ratio (2.13) is close to dentistry's (2.28) — but this paper does not yet have an established, externally corroborated mechanism explaining the PT gap, and substituting a denominator without one would be substituting to match a result rather than a documented cause. Figures 2 and 3 are accordingly illustrative sensitivity displays that disclose this one deliberate exception, not a second formal ranking; the formal rankings a reader should treat as authoritative are Table 4/Appendix A2 (CMS), Appendix A3a (NPPES), and Appendix A3b (BLS, uniform across all 15 fields) — each internally consistent on a single denominator throughout. See §5 for the resulting BLS-ranking change and Appendix A6 for the full sensitivity table.

2.5 Severity Measures

Mean malpractice payment equals the sum of range-coded payment values divided by the number of malpractice reports with payment data. Amounts are nominal and not inflation-adjusted. Mean action length uses only records for which an action length is coded as specified; permanent, indefinite, and non-specified sanctions are not represented in the mean. Known outcome severity uses NPDB outcome values 1–9, with higher values indicating more severe injury. Value 10 (“Cannot Be Determined from Available Records”) is excluded from the mean and counted separately.

The Section 7 payment-severity ranking is restricted to independently practicing fields of licensure with at least 100 malpractice payment reports in 2023–2025. This rule explicitly excludes Physician Resident (licnfeld 15): a resident is a training-status code rather than an independent field of licensure comparable to the other 14 fields in that ranking, so it is excluded by the same logic that would exclude a dental or nursing residency code, not as an ad hoc adjustment. Applying this rule yields 14 qualifying fields; including Physician Resident would yield 15. This rule is stated here, in Methods, rather than left implicit in the ranking itself.

2.6 Analytic Approach and Interpretation

The paper reports counts, percentages, pooled rates, ratios, three-year averages, and descriptive rank order. No inferential statistical tests are applied because the supplied data are a public-use census of reports rather than a probability sample and because denominator definitions differ in coverage. Distinct-practitioner counts are not summed across aggregate cells: COUNT(DISTINCT) values are nonadditive across years, states, event years, and report categories. Accordingly, this paper describes reports, not unique affected practitioners, unless explicitly stated. This draft was produced using a multi-stage, AI-assisted process consistent with Research Library Governance Framework §12; the full independent-verification and reconciliation record is maintained in the internal AI Assistance and Reproducibility Record kept under that Framework, and is also provided in Appendix B of the working DOCX for DAWG review.

Results

3. National NPDB Activity, 2010–2025

Individual-practitioner fields generated 1,105,678 reports during 2010–2025. Licensure actions dominated the record at 768,279 reports (69.5%), followed by malpractice payments at 188,107 (17.0%), exclusions at 92,941 (8.4%), government administrative actions at 26,357 (2.4%), clinical-privileges actions at 21,147 (1.9%), DEA actions at 7,917 (0.7%), and professional-society actions at 930 (0.1%). The report-type correction in this revision changes category composition but not the 1,105,678-report total.

Annual processed volume fell 28.3%, from 89,973 in 2010 to 64,508 in 2025. The decline was concentrated in licensure actions, which fell 35.1%; malpractice payment reports fell 12.9%. Nominal coded malpractice payments moved in the opposite direction: total coded payments rose 42.0%, and the mean coded payment increased from approximately $280,728 to $457,483. These values are not inflation-adjusted and should not be interpreted as real-dollar claim severity.

Table 2. Selected national processing-year activity, individual-practitioner fields.

Source: corrected NPDB v2.2 aggregate extract. Mean payments are nominal range-coded values. Full 2010–2025 series in Appendix A1; table omits partial-year 2026.

Processing-year decline should not be read as a one-for-one decline in underlying adverse events. Between 2010 and 2019, processed adverse-action reports fell from 76,766 to 58,816 (−23.4%), while adverse actions grouped by event year increased from 53,587 to 55,884 (+4.3%). The early processing-year peak therefore includes substantial reporting-lag or backlog effects. Malpractice event-year data after approximately 2020 are incomplete and are not used for recent trend conclusions.

4. Volume and Report Mix Across Fields of Licensure

Raw volume is concentrated in large licensed workforces. Registered nurses generated 256,427 reports during 2010–2025; MD physicians generated 233,507, and DO physicians another 23,386. LPN/LVNs generated 146,399. These counts are not rates: they combine workforce size, reportability rules, repeated reports, and profession-specific regulatory structures.

Table 3. Historical volume and report mix for selected fields, 2010–2025.

Percentages are shares of each field's total reports; remainder is clinical-privileges, professional-society, DEA, government administrative, and other categories. Physicians (MD, DO) shown separately. Rows for DC and PT are the paper's principal comparison.

The category mix separates fields into recognizable reporting profiles. Physicians, podiatrists, CRNAs, and nurse midwives are malpractice-intensive. Nursing, pharmacy, therapy, and behavioral-health fields are licensure-intensive. Nursing assistants and direct-care occupations have a larger exclusion component. Chiropractic is comparatively mixed: during 2010–2025, 17.7% of DC reports were malpractice payments, 60.8% licensure actions, 5.4% clinical-privileges actions, 2.7% government administrative actions, 13.3% exclusions, and 0.0% DEA actions. PT reports were more concentrated in licensure actions: 13.5% malpractice, 77.1% licensure, 1.9% privileges, 2.3% government administrative actions, 5.2% exclusions, and 0.0% DEA actions. The corrected extract therefore shows that the apparent DC/PT “DEA” activity in earlier versions was entirely reptype 604 government administrative activity, not DEA action reports.

5. Denominator-Adjusted Activity, 2023–2025

The denominator-adjusted analysis materially changes raw-volume ranking but does not produce a single definitive profession-risk ranking. CMS counts Medicare-enrolled providers; NPPES counts active individual NPI records; BLS estimates employed workers. Each denominator answers a different question. Table 4 reports pooled 2023–2025 reports per 10,000 provider-years for 15 fields with direct or validated CMS crosswalks; MD and DO are combined for this table only, consistent with the CMS enrollment denominator.

Table 4. NPDB reports per 10,000 CMS-enrolled provider-years, 2023–2025.

CMS rates are not rates per active licensee. CMS may substantially undercount fields with limited Medicare participation, especially dentists, pharmacists, social workers, SLPs, OTs, and psychologists. Full NPPES and BLS rankings in Appendix A3.

Under the CMS definition, chiropractic ranked fourth at 133.4 reports per 10,000 provider-years, below dentists, pharmacists, and podiatrists and above the combined physician rate of 125.2. Physical therapy ranked 11th at 37.8. Chiropractic also ranked fourth under NPPES, at 67.5 per 10,000 active NPI-years — there it sits below podiatry, physicians, and dentistry, and above pharmacy, an ordering that differs from CMS's because the two denominators capture different populations (§2.4); PT ranked 12th under NPPES. Under a corrected 2025 BLS employment view (§2.4, Appendix A3b), chiropractic ranks second at 194.4, just above dentistry's corrected rate of approximately 191.5 and below only podiatry; PT ranks 12th under BLS as well. Chiropractic's consistently top-tier position is therefore not an artifact of one denominator source, but its exact rank relative to dentistry, pharmacy, and physicians is denominator-dependent and should not be treated as a single fixed ordering; the absolute rates themselves are also denominator-specific and should not be compared across sources as if the underlying populations were identical.

Dentistry's first-place CMS rate warrants a specific caveat, distinct from the general denominator caution above. CMS's Medicare-enrollment denominator is a documented undercount for dentistry, because Medicare covers little routine dental care and most practicing dentists never enroll in PECOS. Substituting BLS employment for dentistry's denominator produces several different, correctly-labeled rates depending on which figure or table is being read, and none of them should be confused with the others: Table 4's CMS-based rate is 423.3 per 10,000 provider-years; Figure 2's BLS-based rate, pooling three years by tripling the single 2025 BLS estimate, is 186.0; Appendix A3b's pure 2025 BLS rate (no tripling) is 191.5; and Figure 3's 2025 BLS-based rate is specifically a malpractice-report rate, 80.3, not a total-report rate and not comparable to the other three. Under any of the BLS-based figures, correcting the denominator roughly halves dentistry's apparent rate relative to the CMS view — the largest positive BLS-to-CMS denominator discrepancy in this comparison, per Appendix A6 (podiatry's ratio points the opposite direction and is larger in magnitude, but that is a separate finding, discussed in Appendix A6, not acted on here). This does not change dentistry's position relative to chiropractic or physical therapy under a consistent single denominator, and Table 4 is not altered on this basis; it does mean dentistry's specific first-place margin in Table 4 should be read with more caution than the other rankings in that table. Figures 2 and 3 apply the BLS substitution directly for this reason (§2.4).

Table 5. DC–PT denominator sensitivity.

Rates are per 10,000 denominator units. BLS is 2025 only and uses a materially smaller chiropractic denominator than CMS or NPPES, which inflates the BLS DC/PT ratio; the BLS view should be read as directional confirmation, not a precise third estimate. The three “rank of 15” rows below are each within their own denominator-specific comparator set, not a shared 15-field population across all three (§2.4).

6. Chiropractic and Physical Therapy: Longitudinal Comparison

Raw chiropractic report volume declined substantially over the study period, while physical-therapy volume was comparatively stable and then increased. Comparing three-year averages reduces the influence of single-year batch reporting. DC total reports averaged 1,292 annually in 2010–2012, 796 in 2017–2019, and 667 in 2023–2025. PT averages were 416, 413, and 476. The DC decline was driven primarily by licensure actions and exclusions; DC malpractice volume was essentially unchanged at 166 reports annually in 2010–2012 and 165 in 2023–2025.

Table 6. Average annual DC and PT reports in selected three-year periods.

Three-year averages use processing-year reports. “Mal.” = malpractice payment reports; “lic.” = licensure actions.

Recent annual rates show a widening DC–PT difference. Under CMS, the total-rate ratio rose from 3.09× in 2023 to 4.08× in 2025; under NPPES it rose from 3.23× to 4.09×. The pattern was driven by increased DC licensure actions and total reports in 2025, not by a comparable change in PT activity. The 2025 CMS DC denominator also declined slightly, but the same rate increase appears under the expanding NPPES denominator, so denominator contraction is not the sole explanation.

Table 7. DC and PT report mix, 2023–2025.

The five displayed categories account for essentially all DC and PT reports in the period. True DEA actions were 0 for both fields in 2023–2025; the 8.6% DC and 5.3% PT shares previously labeled DEA are government administrative actions under reptype 604. Shares are within profession, not population rates.

7. Payment and Severity Profile

Severity measures are descriptive attributes of reports, not population rates. For 2023–2025, DC malpractice payment reports averaged $216,351 in range-coded nominal payments, 58% above the PT mean of $136,633. Among fields with at least 100 malpractice reports, DC ranked 10th of 14 by mean payment and PT 13th; the 14-field cohort excludes Physician Resident (licnfeld 15), a training-status code, from an otherwise complete individual-practitioner set, per the explicit rule stated in §2.5. Physicians, nurses, advanced-practice clinicians, and podiatrists generally had higher mean coded payments; dentists were similar to PTs.

Table 8. Selected DC and PT severity measures, 2023–2025.

Outcome value 10 (“Cannot Be Determined from Available Records”) is excluded from the 1–9 mean and reported separately as unknown share. Mean specified action length uses only records with a coded, finite-duration sanction (aalentyp = 'S'); permanent, indefinite, and non-specified sanctions are excluded (§2.5).

The outcome missingness difference is itself a substantive data-quality finding. Ninety-five of 494 DC malpractice reports were coded “cannot be determined,” compared with zero of 193 PT reports. That pattern could reflect differences in underlying cases, reporting organizations, coding practice, or data extraction. It prevents a strong conclusion that the observed outcome-score difference represents a true difference in injury severity.

Among the smaller subset of reports with a specified, finite-duration action length, DC's mean was 2.67 years (n=202) versus PT's 1.02 years (n=287) — DC's mean specified sanction was roughly 2.6× longer. This measure covers only a fraction of each field's 2023–2025 reports (202 of 2,002 DC reports; 287 of 1,429 PT reports, Table 7) because most licensure and other adverse actions are coded as permanent, indefinite, or otherwise non-specified rather than as a finite term, so it should be read as a narrow, secondary severity indicator alongside payment amount and outcome severity, not a comprehensive one.

8. What the NPDB Comparison Does — and Does Not — Establish

The most defensible interpretation is that chiropractic occupies a higher NPDB reporting position than physical therapy across multiple report categories and denominator sources. CMS and NPPES produce highly consistent DC/PT relative ratios (3.53× and 3.59× for total reports; 6.44× and 6.57× for malpractice); BLS is directionally concordant — chiropractic remains well above physical therapy — but materially larger (10.44× and 20.94×), for the denominator reasons Table 5 explains. The data also show that chiropractic is not the highest-rate field: its position is below podiatry under every denominator view, and below some but not all of dentistry, pharmacy, and physicians depending on which denominator is used (§5, Appendix A3). Its report profile is mixed rather than dominated by malpractice alone.

The analysis does not establish comparative clinical safety. The NPDB numerator lacks patient encounters, procedures, exposure time, diagnosis, case complexity, payer mix, practice setting, board enforcement intensity, or a stable unique-practitioner denominator. One practitioner may produce multiple reports, and one underlying episode may generate more than one report type or action. A valid clinical-risk comparison would require exposure-adjusted event definitions and a design capable of separating professional practice from regulatory and reporting systems.

Key Limitations

• Reports are not practitioners: a single practitioner may generate multiple NPDB reports. Aggregate distinct-practitioner counts cannot be summed across cells, so this paper does not report a national proportion of practitioners with reports.

• Denominators are not active licenses: CMS counts Medicare-enrolled providers, NPPES counts active NPI records, and BLS estimates employed workers. Each excludes or includes different populations.

• No exposure denominator: the data contain no patient visits, procedures, clinical hours, or service intensity. Rates are per provider denominator, not per unit of clinical exposure.

• Processing-year artifacts: annual processing volume can reflect reporting lag, batch submissions, backlog clearance, or policy changes. Event-year malpractice data are incomplete for recent years.

• Structural break: the May 2013 HIPDB merger expanded NPDB scope. Longitudinal comparisons spanning the merger should not be interpreted as a homogeneous reporting regime.

• Payment coding: malpractice payments are range-coded values and are not inflation-adjusted. Means can be influenced by top-coded or broad payment bands.

• Severity selection: known outcome severity applies only to malpractice reports with values 1–9. Unknown coding is nonrandom and was particularly common among recent chiropractic reports (19.2% vs. 0.0% for PT).

• Action-length selection: mean action length includes only specified-duration actions and omits permanent, indefinite, stayed, or otherwise non-specified sanctions.

• Report-type classification correction: this revision separates individual DEA actions (reptypes 601/602) from Government Administrative actions (reptype 604). Earlier category-specific DEA labels should not be used; total report counts and total-rate findings are unchanged.

• Crosswalk imprecision: external taxonomy and provider-type mappings do not perfectly reproduce NPDB fields. Physician MD and DO numerators are combined for CMS and NPPES rate tables; advanced-practice nursing categories can overlap or be classified differently across external denominator sources.

• Partial source inconsistency: the methods describe PBJ coverage from 2017–2026, but the supplied workbook contains 2021 only. PBJ is not used in the headline analysis.

• Aggregate extract: the supplied data are aggregate cells, not record-level reports. Practitioner concentration, serial reporting, episode linkage, and exact state-level reconciliation cannot be reconstructed from the aggregate file alone.

• Severity-ranking cohort: the “fields with ≥100 malpractice reports” cohort used for the payment-rank statistic (Section 7) excludes Physician Resident (licnfeld 15) by the explicit rule stated in §2.5 (independently practicing fields of licensure only).

• Dentistry denominator substitution: Figures 2 and 3 use BLS 2025 employment, not CMS enrollment, as dentistry's denominator (§2.4, §5), because CMS undercounts dentistry for a documented reason (limited Medicare dental coverage). The BLS denominator uses the broad Dentists occupation (SOC 29-1020, 141,610), matching NPDB licnfeld 30's scope of general dentistry plus dental specialties (§2.4). Figure 2 additionally approximates a 2023–2025 provider-year quantity by multiplying the single 2025 BLS estimate by three, assuming stable dentist employment over the period — a reasonable but disclosed approximation, not a measurement, and applied to no other field. Table 4 and Appendix A2 are not adjusted on this basis and retain CMS for all 15 fields including dentistry. Four different, correctly-labeled dentistry rates appear in this paper and should not be confused with one another (§5): Table 4's CMS rate (423.3), Figure 2's pooled BLS rate (186.0), Appendix A3b's single-year BLS rate (191.5), and Figure 3's BLS-based malpractice rate specifically (80.3, not a total-report rate).

• Dual-licensed oral/maxillofacial surgeons: some OMS hold both dental and medical (MD) credentials, and the NPDB Public Use File does not indicate which license a given dual-licensed OMS's report was associated with. NPDB licnfeld 30 (Dentist) therefore may capture some but not all practicing OMS — an unknown share of OMS reports may instead appear under licnfeld 10 (Physician). This is a numerator-side imprecision that neither the CMS nor the BLS denominator correction addresses (§2.4).

• PT's own CMS/BLS denominator ratio (2.13, Appendix A6) is close to dentistry's (2.28) but is not substituted in this paper. This is not because PT is a secondary comparator — it is one of the paper's two principal comparators — but because dentistry's CMS undercount has a specific, externally documented mechanism (§2.4: limited Medicare dental coverage, corroborated by ADA Health Policy Institute's independent workforce count), while this analysis does not establish what causes PT's gap. Substituting a denominator without an established mechanism would be substituting to match a result rather than a documented cause; this is disclosed as an open item for future investigation, not resolved here.

Disclosures and Publication Status

This work is classified as a public-data workforce, regulatory, and health-services analysis under the Arete Research Library Governance Framework; it is not PBRN-sponsored human-subjects research. Arete Healthcare supports independent outpatient chiropractic and physical therapy practices and has a commercial and professional interest in practice infrastructure, interoperability, compliance, analytics, and payer contracting. AI tools assisted with data review, calculation, and drafting. Every factual assertion and calculation requires responsible human verification before publication, and AI-assisted reconciliation does not substitute for an Independent Data/Methodology Reviewer or DAWG approval.

Recommended citation: Arete Healthcare. The Regulatory Record: National Practitioner Data Bank Volume, Mix, and Severity Across Healthcare Fields of Licensure, 2010–2025. Arete Original Research ARETE-OR-2026-006, Version 3.4. Revised September 2026 (reptype 604 correction, DAWG-approved); original publication August 20, 2026. https://doi.org/10.13140/RG.2.2.13024.03841

References

1. Health Resources and Services Administration. National Practitioner Data Bank Public Use Data File. https://www.npdb.hrsa.gov/resources/publicData.jsp

2. Health Resources and Services Administration. NPDB Public Use Data File Codebook and Public Use File Format Specifications. Division of Practitioner Data Bank.

2a. American Medical Association Journal of Ethics. The National Practitioner Data Bank: Promoting Safety and Quality. 2004;6(3). https://journalofethics.ama-assn.org/article/national-practitioner-data-bank-promoting-safety-and-quality/2004-03

3. Health Care Quality Improvement Act of 1986, 42 U.S.C. §§ 11101–11152.

4. Centers for Medicare & Medicaid Services. Medicare Fee-for-Service Public Provider Enrollment. https://data.cms.gov/

5. National Plan and Provider Enumeration System. NPI Files. https://download.cms.gov/nppes/

6. Bureau of Labor Statistics. Occupational Employment and Wage Statistics. https://www.bls.gov/oes/

7. Centers for Medicare & Medicaid Services. Payroll-Based Journal Daily Nurse Staffing. https://data.cms.gov/quality-of-care/

8. National Uniform Claim Committee. Health Care Provider Taxonomy Code Set. https://nucc.org/

8a. American Dental Association Health Policy Institute. The U.S. Dentist Workforce: 2024 Update. https://www.ada.org/resources/research/health-policy-institute/dentist-workforce

8b. Bureau of Labor Statistics. Occupational Employment and Wage Statistics, May 2025 National Occupational Employment and Wage Estimates (Table 1, Dentists, SOC 29-1020). https://www.bls.gov/news.release/ocwage.t01.htm

9. Arete Healthcare Research & Analytics. Corrected NPDB v2.2 aggregate extract; NPDB v2.2 methods/SQL; CMS, NPPES, BLS, and PBJ denominator extracts. Internal reproducibility files, September 2026.

Glossary

Appendix A. Supplemental Comparative Tables

A1. Full National Processing-Year Series, 2010–2025

Source: NPDB_History_v3.csv. Individual-practitioner licnfelds only. Payment values are nominal and range-coded.

A2. Full CMS Rate Ranking, 2023–2025

Reproduced from Table 4 in the body for completeness; see Section 5 for interpretation.

A3. NPPES and BLS Sensitivity Rankings

Table A3a. NPPES rates per 10,000 active NPI-years, 2023–2025.

Table A3b. BLS rates per 10,000 employed workers, 2025.

NPPES and BLS rates use different denominator definitions and periods. The tables are sensitivity analyses, not directly combinable estimates.

A4. Full DC and PT Annual Processing-Year Series

Table A4a. Chiropractic (DC), 2010–2025.

Table A4b. Physical Therapy (PT), 2010–2025.

Counts are processing-year reports. The 2011 DC exclusion spike (565 reports, vs. 76–112 in adjacent years) and the 2021 government-administrative shifts (DC 129, PT 36, vs. single digits in prior years) illustrate the importance of examining category composition rather than total volume alone. The corrected extract contains zero DEA actions for both DC and PT during 2010–2025; the values previously shown in the DEA column were reptype 604 government administrative actions.

A5. Recent Severity Ranking for Fields with Adequate Counts

Fields with at least 100 malpractice payment reports in 2023–2025, sorted by mean coded payment. Outcome mean uses known values 1–9; unknown share includes value 10. Physician Resident (licnfeld 15, n=110) is excluded from this table, per the explicit rule stated in §2.5.

A6. CMS/BLS Denominator Sensitivity for Fields with Both Measures

Supports §2.4's analytic rule for the dentistry BLS substitution: this table shows, for every field in Table 4 with both a CMS and a BLS denominator, how far the two disagree. CMS is annualized (pooled 2023–2025 ÷ 3) for comparability with the single-year 2025 BLS estimate. A ratio near 1.0 means the two sources roughly agree; ratios well above or below 1.0 mean the sources disagree materially about the size of that field's workforce.

Dentistry's ratio (2.28) and Physical Therapist's ratio (2.13) are both notably elevated and not far apart — dentistry is not an isolated outlier in this table. The distinction this paper draws is not the size of the ratio alone but whether an external, documented mechanism explains it (§2.4): dentistry's gap is explained by Medicare's limited dental coverage, corroborated by ADA Health Policy Institute's independently published workforce count. The source of the PT discrepancy is not established by these data and warrants separate investigation; this paper does not substitute PT's denominator, and Figures 2–3 should be read as illustrative sensitivity displays of the dentistry case specifically, not as a signal that every large ratio in this table has been corrected for. Podiatrist's low ratio (0.37) may partly reflect BLS OEWS's exclusion of the self-employed in a field with a high solo/small-practice share; the cause is not established by these data and, consistent with the standard applied to PT above, is not asserted as confirmed. It is not treated as evidence CMS is wrong for podiatry, only that the two sources measure different things.