Summary
A collaborative practice agreement defines the working relationship between a nurse practitioner (NP) and a collaborating physician. It must include scope of practice, prescriptive authority, communication expectations, and supervision protocols. Requirements vary by state.
What Is a Collaborative Practice Agreement?
After you find a collaborating physician, the legal structure of the oversight needs to be established. A collaborative practice agreement (CPA) is a legal document that outlines the professional relationship between a nurse practitioner (NP) and a collaborating physician. It defines the NP’s scope of practice, consultation expectations, and prescriptive authority.
These agreements are required in many states for NPs to practice and prescribe medications—especially controlled substances—and are a key compliance document during board audits or DEA registration.
Why the Level of Detail in the Agreement Matters
Collaborative practice agreements for nurse practitioners can range from one-page forms with vague phrases like “NP can practice within scope” to detailed, multi-page documents listing specific treatments, medications, and clinical settings.
In our experience, the most defensible agreements strike a middle ground. Overly vague documents often attract board scrutiny, as they may suggest that the physician isn’t meaningfully involved. This can raise red flags about the legitimacy of the collaboration and the level of physician oversight. On the other hand, overly rigid agreements may constrain the NP’s clinical flexibility or unintentionally limit services that fall within their scope of practice.
A well-written collaborative practice agreement should provide enough specificity to demonstrate a genuine, informed relationship between the NP and the physician, while leaving room for professional judgment and practice growth. The agreement should reflect real-world clinical activities and showcase shared responsibility—not just serve as a formality to meet board requirements.
Common Mistakes to Avoid in Collaborative Practice Agreements
Even well-intentioned providers can make mistakes when drafting or managing a collaborative practice agreement. Here are some of the most common errors we see—and why they can lead to serious consequences:
1. Using Language That Is Too Vague
Statements like “NP will practice within their scope” or “follows standard guidelines” may seem sufficient, but they lack specificity. Boards reviewing these agreements may view vague language as a sign that the physician isn’t actively engaged or aware of the NP’s daily responsibilities. This can lead to fines, investigations, or delays in DEA licensing. Instead, provide concrete examples of the services the NP provides, the settings in which they work, and how oversight will be conducted.
2. Not Filing or Reporting the Agreement When Required
Some states, such as Georgia, require the agreement to be filed with the Board of Medicine or Board of Nursing before the NP can begin practicing. Others may require reporting the collaborative relationship even if the agreement itself is kept on file. Failing to submit or report this information when required can render the agreement invalid and put the NP at risk of practicing without legal authorization.
3. Documenting Oversight Requirements but Not Following Through
Many agreements outline supervision activities like chart reviews, site visits, or monthly check-ins—but in practice, these steps are skipped or forgotten. This discrepancy becomes a major liability during board investigations. If your agreement says chart reviews will occur quarterly, you must have dated documentation showing they occurred. Boards don’t just care what’s on paper—they want proof that it’s happening.
4. Missing Signatures and Dates
It may sound basic, but this is one of the most frequent issues we see. An unsigned or undated agreement may be viewed as never having gone into effect. During an audit, regulators will look at signature and effective dates to determine whether the NP was authorized to practice at a specific time. Without clear signatures and dates, the agreement may be invalid retroactively.
5. Letting the NP Start Practicing Before the Agreement Is Finalized
This happens more often than it should: the NP is ready to work, and everyone agrees on the terms, but the paperwork hasn’t been signed or filed. Allowing the NP to begin patient care before the agreement is complete and legally in effect is a major compliance risk. In states that require board approval or filing, the NP must wait until the agreement is officially accepted.
Avoiding these mistakes not only keeps you compliant but protects both the NP and the physician from legal and licensure consequences.
What Should Be Included in a Nurse Practitioner Collaborative Practice Agreement?
Here are the essential sections every CPA should include:
1. Contact Information & Licensure Details
Include the names, credentials, license numbers, and contact details for both the NP and the collaborating physician. This is foundational information for identifying both parties and ensuring their licensure is active and appropriate for the collaborative relationship.
2. Scope of Practice
Clearly define the services, procedures, and patient populations the NP is expected to manage. This could include specific treatments (e.g., chronic disease management, women’s health, urgent care), clinical settings (e.g., outpatient clinic, mobile health unit), and any service limitations. Vague phrases like “within scope” should be avoided or supported with examples. This section should reflect the NP’s training and expertise while showing that the physician understands and supports those activities.
3. Prescriptive Authority
State whether the NP has authority to prescribe medications, including controlled substances. If the NP is prescribing Schedule II–V drugs, the agreement should specify this and include any state-specific limitations or requirements. Additionally, it should note whether the NP must obtain a DEA number and whether the physician is expected to co-sign or review prescriptions under certain conditions.
4. When and How the Physician Must Be Contacted
Outline the clinical scenarios in which the NP should consult the physician. This may include initiating complex treatments, making diagnoses that carry high risk, prescribing high-risk medications, or when uncertain about clinical decisions. Also define how contact should occur—via phone, secure messaging, email, or in-person—and expected response times. This section helps document the collaborative nature of the relationship and reinforces accountability.
5. Supervision & Chart Review Requirements
Define how the physician will review the NP’s work. Many states require a percentage of chart reviews—10% quarterly is common—but even where not mandated, regular oversight is advisable. Detail what types of encounters are reviewed (e.g., new patients, controlled substance prescriptions) and how feedback is shared. Specify how reviews are documented to protect both parties during board inquiries.
6. Backup/Alternate Physician Coverage
One of the most overlooked yet critical elements of a collaborative practice agreement is what happens when the collaborating physician is unavailable. If a physician takes a vacation, becomes ill, or is otherwise unreachable, the NP may be legally required to suspend patient care—unless a backup or “covering” physician is designated in the agreement.
This section should name the alternate physician, provide their licensure details, and outline when and how they will step in. The backup physician should agree to the same expectations around availability and oversight, even if only temporarily. Without this provision, a clinic can be forced to pause operations or risk practicing out of compliance. Including a backup shows thoughtful risk planning and a commitment to continuous patient care.
7. Renewal, Termination & Amendments
The collaborative practice agreement should be reviewed and re-signed annually. Many states require this, and even where it’s not mandatory, it’s a best practice. This annual review provides an opportunity to make updates based on changes in practice scope, clinic operations, or state regulations.
The agreement should include a termination clause (e.g., either party may terminate with 30 days’ notice) and specify how amendments should be documented. This reinforces that the agreement is a living document that should grow and evolve as the NP’s role expands.
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Can You Get a DEA License Without a Collaborative Practice Agreement?
In states that require a collaborative practice agreement, the document must be signed and in effect before an NP can apply for DEA registration. DEA applications may be delayed or denied if there’s no documentation proving the NP has been authorized to prescribe controlled substances.
The collaborative practice agreement should include specific language supporting prescriptive authority for controlled substances and indicate that the physician agrees to the NP’s use of a DEA license.
Do You Need to File a Collaborative Practice Agreement with the State?
Filing requirements vary significantly by state. Some states require the agreement itself to be filed with the Board of Nursing, Board of Medicine, or both. Others only require the relationship to be reported, while allowing the agreement to be kept on file at the practice.
For example:
- Georgia requires a state-specific collaborative practice agreement form to be completed, signed, and submitted before the NP is legally allowed to practice.
- Other states, like Florida or Texas, may require only notification of the collaborative relationship.
NPs and collaborating physicians must confirm their state’s specific process, including whether the agreement must be submitted, retained on-site, or reviewed by legal counsel. GuardianMD tracks all 50 state requirements to help clients stay compliant.
Can You Use One Collaborative Practice Agreement for Multiple Clinics?
In most cases, no. If a nurse practitioner works for two separate legal entities—such as a mobile IV clinic and a telehealth platform—they will typically need separate collaborative practice agreements for each.
Even if the same physician collaborates across both roles, state laws generally tie collaborative practice agreements to a specific employment or practice arrangement. A single “universal” CPA risks noncompliance and could lead to delays with licensing, audits, or insurance credentialing.
How Often Should a Collaborative practice agreement Be Reviewed or Updated?
It is best practice to revisit and re-sign the collaborative practice agreement at least once per year. This not only satisfies most regulatory requirements but provides a structured opportunity for the NP and physician to reflect on how the relationship is working.
Regular reviews allow:
- Updates to services, procedures, or medications offered
- Reassessment of oversight and communication expectations
- Changes to chart review processes or coverage arrangements
Boards often ask for documentation of ongoing collaboration—especially during investigations. Reviewing and updating your CPA annually is one of the most defensible steps you can take.
Do You Need an Attorney to Draft a Collaborative Practice Agreement?
It’s not typically necessary to involve an attorney unless there are unique legal considerations. Most nurse practitioners and physicians can draft a compliant and protective agreement using a strong template and guidance from reliable sources.
GuardianMD provides state-specific collaborative practice templates to clients and walks both parties through the key terms and legal requirements. Unless your practice setup is especially complex or involves unusual risk, you likely do not need to hire legal counsel.
FAQs
Do I need a collaborative practice agreement to get a DEA license?
Do I need a collaborative practice agreement to get a DEA license?
Can I use one CPA for multiple jobs?
Not typically. Separate jobs (legal employers) require separate agreements, and sometimes the assigned physician will only oversee you for the respective job.
Who signs the collaborative practice agreement?
Both the NP and the collaborating physician. Most boards accept electronic signatures. Some states allow you to keep a copy on file for your records and don’t require it to be submitted to the board.
How often should it be reviewed?
Your collaborative practice agreement should be reviewed at least annually, or as required by state regulation
Is legal review necessary?
Legal review is not usually required. Most NP-physician teams can complete it on their own using a solid template and board guidance.
Call to Action:
Do you need a collaborating physician or want help navigating your state’s requirements? Partner with GuardianMD for templates, oversight, and expert support in all 50 states.
About the Author
Christopher Seitz, MD is the Founder, CEO and Chief Medical Officer of GuardianMD and a national leader in medical oversight, compliance, and corporate practice of medicine structures for nurse practitioners and non-physician-owned clinics. Dr. Seitz is a board-certified Emergency Physician that holds active medical licenses in all 50 U.S. states. He is functional medicine trained as well and serves as a compliance advisor to health entrepreneurs, medical boards, and oversight organizations nationwide.
GuardianMD provides fully insured, board-ready collaborating physicians in all 50 states, along with downloadable agreement templates and ongoing support to help NPs stay compliant and grow their practice.