380, 368 S.E.2d 268 (1988). After finding that Philip Morris negligently hired a subcontractor, A-Line, by failing to investigate at all A-Line’s qualifications for the dangerous work being performed, the Court stated “[mjoreover, [Philip Morris] negligently failed to discharge A-Line after observing a number of incidents demonstrating A-Line’s incompetence and negligence in dealing with the dangerous chemicals.” Philip Morris at 400, 368 S.E.2d at 278. The Supreme Court recognized that it had not ruled directly on such an issue previously, but it had “invoked the underlying rationale for the tort of negligent retention” in the context of charitable institutions. Id. at 401, 368 S.E.2d at 279 (citing Norfolk Protestant Hospital v. Plunkett, 162 Va. 151, 155-56, 173 S.E. 363, 365 (1934) (<HOLDING>)). The Court in Philip Morris cited an Ohio
holding that a nurse practitioners opinion constituted an acceptable medical source where the nurse worked closely under the supervision of the doctor such that the nurse was acting as an agent of the doctor holding protected a television interview in which a nurse complained of hospital staff shortages and suggested that they were related to low pay holding jury was warranted in finding hospital negligent in its selection and retention of a nurse after the nurse violated hospital rules and had been repeatedly reprimanded but not fired holding that where hospital used balance billing that since the hospital had already received payments from the patient and his health insurer and had agreed to accept that amount as payment in full for its services there was no longer any amount owing to the hospital and thus it could not assert a statutory hospital lien for the difference between its charges and the amount received in light of the negotiated network agreements holding that plaintiff director of security for a hospital had sufficiently pled requisite public policy and a close fit where he asserted that a hospital fired him for reporting to law enforcement that a hospital administrator bribed a public official