COVID-19 State Emergency Response: Temporarily Suspended and Waived Practice Agreement Requirements

Updated April 3, 2020 at 2:15 p.m.

Legend

Temporary suspension of all practice agreement requirements
Temporary waiver of select practice agreement requirements
Currently no action on this issue
Full Practice Authority States

This map and table below provide links to specific information in the states.

As states temporarily suspend or waive existing collaboration, supervision and protocol requirements this page will be updated. Last update April 3, 2020 at 2:15 p.m.

AlabamaAccording to the fifth Supplemental Guidance Issued April 2 in response to Governor Ivey’s State of Emergency Declaration and Executive Orders and the Alabama Board of Nursing:

Alabama Practice Settings within Licensed healthcare facility (LHF):

Temporary Suspension of Practice Agreement Ratio Limits and Reporting/Recordkeeping for NPs
  • Ratio: Licensed healthcare facility (LHF)-based NP practice allows collaboration with the Chief Medical Officer or designee, which may be in specific patient locations within the hospital such as Emergency Department, Intensive Care Unit or elsewhere in the facility. Allows for the CMO or designee to have unlimited collaborations.
  • Recording: A facility can have an unlimited number of CRNP/CNM. An application is not required as the LHF will perform record keeping for this. There is no fee associated with the LTF approval during this crisis period.
Temporary Authorization for CRNPs In Select Facilities to Provide Select Additional Care Services
  • NPs authorized to prescribe from a facility-approved formulary and perform all skills authorized in the facility protocols within the scope of the NP’s education and training. (controlled substance prescribing requires DEA registration through the ABME).
  • The facility is authorized to develop related CRNP/CNM protocols supportive of patient care, based on the scope of practice for a CRNP/CNM.
Alabama Practice Settings Other than Licensed Healthcare Facilities:

Temporary Increase to 1:9 Practice Agreement Ratio in Care Settings Other Than Select Facilities
  • Authorizes ratio of one physician collaborator to nine FTE NPs in care settings outside of licensed healthcare facilities; authorizes temporary emergency practice agreement application and expedited joint Board approval.
ArkansasPursuant to the Governor's Executive Order 20-06
  • The Arkansas Board of Nursing has suspended the requirement that APRNs shall submit evidence of a current collaborative practice agreement as a prerequisite to license renewal through April 16, 2020.
No other changes or waivers to collaborative/supervision/protocol agreements were made. NPs must maintain other elements of collaborative agreements, supervision or protocol in existing law/regulation.
IndianaIndiana State Board of Nursing Executive Order Waiver 001
  • Authorizes temporary suspension of the requirement APRNS submit documentation within 7 days to a physician in an agreement of prescribing practices and 5% minimum chart reviews.
Executive Order No 20-5
  • Waives requirement for Indiana APRNs to maintain multiple practice agreements for additional practice locations during the emergency.
No other changes or waivers to collaborative/supervision/protocol agreements were made. NPs must maintain other elements of collaborative agreements, supervision or protocol in existing law/regulation.
Kentucky

Practice Agreement Requirements Temporarily Waived

LouisianaExecutive Order Proclamation Number 38 JBE 2020
  • Section 2B suspends the collaborative practice agreement requirements of the LA State Board of Medical Examiners and Board of Nursing for APRNs for the duration of the public health emergency.
MaineExecutive Order No. 16 FY 19/20
  • All mandatory supervision or collaborative practice requirements are suspended for qualified APRNs assisting or who will assist with COVID-19 response for the duration of the emergency declaration.
  • Executive Order directs Maine Board of Nursing to issue appropriate guidance to applicants and licensees. More information can be found here.
Massachusetts

Emergency Order

  • Suspend the requirements for physician supervision and written guidelines for prescriptive practice for APRNs who have at least 2 years of supervised practice experience.
  • Supervision requirements remain in place for APRNs with less than 2 years of practice. Some documentation requirements have been adjusted during this emergency. See order for documentation requirements.

Michigan

Executive Order No. 2020-30

  • Temporarily authorizes suspension of supervision and delegation requirements for Michigan APRNs by select facilities at which the professional is employed or contracted to work.
MissouriDHSS Waiver
  • Requirement for collaborating physician to review a minimum of 10% of charts every 14 days. Waiver does not include the review of the percentage of cases where the APRN prescribed controlled substances.
  • Requirement for an APRN to practice with the collaborating physician continuously present for at least one month.
Executive Order 20-04
  • Missouri has temporarily waived the requirement for an APRN to practice within 75 miles of the collaborating physician.
No other changes or waivers to collaborative/supervision/protocol agreements were made. NPs must maintain other elements of collaborative agreements, supervision or protocol in existing law/regulation.
New JerseyEXECUTIVE ORDER 112
  • Suspends requirement for NPs to have joint protocol with a collaborating physician, requirement for chart review, requirement for physician name on prescriptions, and waives rule requiring APNs to obtain authorization from a collaborating physician in order to dispense narcotic drugs.
New YorkExecutive Order No 202.10
  • Suspends requirement for written practice agreement or collaborative relationship with a physician until April 22, 2020.
PennsylvaniaExecutive Order
Certified Registered Nurse Practitioners (CRNPs) The Department also requested suspension of certain requirements for CRNPs as follows:
  • Restrictions requiring a CRNP practice within a specific clinical specialty are suspended.
  • Restrictions which prohibit CRNPs from prescribing drugs outside of the established formulary are suspended.
  • On an initial application for prescriptive authority, the State Board of Nursing will require only one collaborative physician and one substitute physician.
  • During the emergency period, for changes to an existing prescriptive authority collaborative agreement (PACA), the Board of Nursing will suspend Board pre-approval requirements for the following:
    • Deletion or addition of drug categories
    • Change of controlled substances
    • Deletion or addition of substitute physicians
    • Changes to the circumstances and how often the collaborating physician will personally see the patient
    • Termination of the PACA
  • For an additional prescriptive authority authorization, if a CRNP has one active Pennsylvania prescriptive authority with a physician, the CRNP, upon application, will be permitted to practice with a new collaborating physician for up to 6 months provided the CRNP and the new collaborating physician hold current unrestricted licenses.
No other changes or waivers to collaborative/supervision/protocol agreements were made. NPs must maintain other elements of collaborative agreements, supervision or protocol in existing law/regulation.
South CarolinaPUBLIC HEALTH STATE OF EMERGENCY ORDER 2020-BON-PH-02
  • Partial suspension only for NC & GA licensed NPs providing care in South Carolina
  • Allows for NPs from North Carolina and Georgia to practice in South Carolina pursuant to their existing collaborative relationships in their home states. Also suspends restrictions on prescribing schedule II & III rx via telemedicine.
No other changes or waivers to collaborative/supervision/protocol agreements were made. NPs must maintain other elements of collaborative agreements, supervision or protocol in existing law/regulation.
TennesseeExecutive Order No. 15
  • Waives the requirement that NPs file notice with the Board of Nursing containing the name of the nurse practitioner, the name of the licensed physician collaborating with the nurse practitioner, and a copy of the formulary describing the categories of legend and non-legend drugs to be prescribed or issued by the nurse practitioner.
  • Waives the requirement for chart reviews.
  • Waives the requirement that a supervising physician visit remotes sites every 30 days during the pandemic.
No other changes or waivers to collaborative/supervision/protocol agreements were made. NPs must maintain other elements of collaborative agreements, supervision or protocol in existing law/regulation.
TexasExisting 22 TAC §172.21 in effect due to state emergency
  • Waives documentation requirements for supervisory arrangements.
No other changes or waivers to collaborative/supervision/protocol agreements were made. NPs must maintain other elements of collaborative agreements, supervision or protocol in existing law/regulation.
Wisconsin

Executive Order 16

  • Suspends requirement for practice agreement or collaborative relationship with other healthcare providers.

DISCLAIMER: The material contained in this is offered as information only and not as practice, financial, accounting, legal or other professional advice. Correspondents must contact their own professional advisors for such advice.