Is <p>&nbsp;</p> to add spacing in website content bad for accessibility?

Example:

<h3>Title</h3>
<p>Stuff here</p>
(more paragraphs and stuff)

<p>&nbsp;</p>

<h3>Next Title</h3>
<p>Stuff here</p>

Basically the title. Currently in the middle of accessibility remediation for my workplace’s website. There’s a check on our automated tool for “All p elements are not used as headers.

Someone mentioned <p>&nbsp;</p> “is more than likely the cause of this issue.🤔

So if it’s bad for accessibility then what are good alternatives to add spacing in page content? I’m a bit confused on this one.
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