Can Nurse Practitioners Practice Independently in Maryland?

Yes. Nurse practitioner independent practice in Maryland is legal and has been since October 1, 2015, when the Nurse Practitioner Full Practice Authority Act took effect.¹ You can evaluate patients, diagnose, order and interpret tests, prescribe, and manage treatment on your own authority. Turning that right into a working practice takes certification through the Maryland Board of Nursing, prescribing registrations, a business entity, provider enrollment, malpractice coverage, and a handful of ongoing obligations.

What Full Practice Authority Covers

The 2015 law repealed the old requirement that every NP maintain a formal collaboration agreement with a physician. In its place, Maryland defined NP practice to include independently conducting physical assessments, establishing medical diagnoses, ordering and interpreting lab tests, prescribing drugs, performing diagnostic and therapeutic measures, and providing emergency care.¹

The Maryland Board of Nursing is the sole regulator. No physician board approval or chart co-signature is required. You are still expected to consult and collaborate with physicians or other providers when clinical circumstances call for it, but that is a matter of professional judgment, not a mandated supervisory arrangement.¹

Getting Certified as a CRNP

Independent practice starts with Certified Registered Nurse Practitioner (CRNP) certification from the Board of Nursing. The requirements are set in Maryland Health Occupations § 8-302.1.² You need:

A current Maryland RN license, or a multistate RN license under the Nurse Licensure Compact.
A graduate degree in advanced practice nursing (MSN or DNP) from an accredited program, with transcript evidence of coursework in advanced pharmacology, advanced pathophysiology, and advanced physical assessment.
A passing score on a national certification exam in your specialty from a Board-recognized certifying body.

Your application packet includes the form, proof of your RN license, an official transcript sent directly from your program, and documentation of your national certification.³

Mentorship for First-Time NPs

If you have never held NP certification in any state, Maryland requires you to identify a mentor before you begin practicing. The mentor must be a Maryland-licensed physician, or a Maryland-licensed NP who has held their license in good standing for at least three years. The mentorship period runs 18 months from the date of your application.³

The mentorship is for consultation and collaboration. Your mentor does not co-sign charts or approve your clinical decisions. You do have to name the person on your application, and the step cannot be skipped. NPs already certified in another state are exempt.

Prescribing and Controlled Substances

Prescribing drugs is part of the NP scope of practice. Board regulations govern the details within each specialty.¹

To prescribe controlled dangerous substances, you need two registrations. The state CDS registration comes from Maryland’s Office of Controlled Substances Administration, and before OCSA will process your application you must first register with Maryland’s Prescription Drug Monitoring Program through the CRISP system.⁴ The federal DEA registration costs $888 for a three-year term and must be tied to each specific practice location where you prescribe.⁵

Two training requirements apply. All DEA-registered practitioners must complete a one-time 8-hour training on treating patients with opioid or other substance use disorders, a federal requirement that took effect with DEA registrations and renewals starting in June 2023. NPs who prescribe CDS must also complete a 2-hour course specifically on dispensing and prescribing controlled substances.

You can dispense starter dosages of medications to patients at no charge if the dosage covers 72 hours or less and you record it in the patient’s chart. Broader dispensing authority applies in specific settings such as nonprofit clinics, public health facilities, and workers’ compensation clinics.⁶

Choosing a Business Structure

Full practice authority gives you the legal right to own and operate the practice. The entity choice affects liability, taxes, and ownership rules.

Maryland does not recognize Professional Limited Liability Companies (PLLCs) as a separate entity type for healthcare professionals. Your realistic options are a standard LLC, a Professional Corporation (PC), or a Professional Association (PA). PCs and PAs restrict ownership to licensed professionals authorized to render the specific service, and a PC can only provide one type of professional service. A standard LLC is more flexible for an NP-owned practice. Work with an attorney familiar with Maryland healthcare entity law so your structure does not run afoul of the corporate practice of medicine doctrine.

Provider Numbers and Payer Enrollment

Every NP needs a Type 1 National Provider Identifier, which identifies you as an individual. If you form an LLC or other entity for the practice, that organization needs its own Type 2 NPI, which requires an Employer Identification Number from the IRS.⁷ Type 2 applications go through the National Plan and Provider Enumeration System and require an authorized official and at least one healthcare taxonomy code.⁸

To accept Medicare patients, enroll through the Provider Enrollment, Chain, and Ownership System (PECOS). Get your NPI first, then set up credentials in CMS’s Identity and Access Management system, then complete the PECOS application matching your practice scenario, such as sole proprietor or group member. CMS requires electronic funds transfer for all Medicare payments, so banking information needs to be ready. If your Medicare Administrative Contractor requests additional documentation after submission, you have 30 days to respond before the application is delayed or denied.⁹

Private insurance credentialing is separate and often slower. Each insurer has its own application, and some take months. Start credentialing well before your opening date, because you cannot bill an insurer for patients seen before your credentialing effective date.

Malpractice Coverage

As an independent practitioner, no employer policy stands behind you. Professional liability insurance is essential, and the policy type matters.

A claims-made policy covers you only if both the incident and the claim fall within the active policy period. When you ever switch carriers, change jobs, or close the practice, you need tail coverage (an extended reporting endorsement) to stay protected against later-filed claims for earlier care. Tail is typically a one-time purchase costing 150% to 250% of your annual premium and lasts indefinitely. An occurrence-based policy covers any incident during the policy period regardless of when the claim is filed, so no tail is needed. Claims-made premiums start lower and escalate; occurrence premiums are higher upfront but more predictable.

Taxes When You Own the Practice

Owning the practice makes you self-employed, and the tax picture shifts from a W-2 position. Self-employment tax applies to net earnings of $400 or more and covers both halves of Social Security and Medicare. The total rate is 15.3%: 12.4% for Social Security and 2.9% for Medicare.¹⁰

The Social Security portion applies only to the first $184,500 of combined earnings in 2026.¹¹ The Medicare portion has no cap. If your net self-employment income exceeds $200,000, or $250,000 for married filing jointly, you owe an additional 0.9% Medicare surtax on the amount above that threshold.¹⁰

You file Schedule SE with your annual return and should make quarterly estimated tax payments to avoid underpayment penalties. First-year owners often underestimate the bill because the self-employed version doubles the payroll tax portion a W-2 employee sees.

HIPAA and Patient Records

An independent practice is a HIPAA-covered entity, and you are personally responsible for the administrative, physical, and technical safeguards under the Security Rule. HHS publishes guidance aimed at small providers, covering access controls, encryption, and workforce training.¹²

No single federal rule sets how long you keep patient records, but HIPAA requires you to protect them for as long as you hold them. Maryland has its own retention standards, and malpractice statutes of limitation set a practical floor. Most practice consultants recommend retaining adult records for at least ten years after the last encounter, longer for pediatric charts. Build the records system before patient volume grows; retrofitting one later is much harder.

Keeping Everything Current

Your Maryland CRNP license expires on the 28th of your birth month and renews biennially. The renewal fee is $216, which includes a Maryland Health Care Commission fee and a preceptorship surcharge.¹³

Maryland does not impose its own state continuing education hour requirement for APRNs. You must maintain your national certification, which carries its own CE requirements. ANCC, for example, requires 75 continuing education contact hours per renewal cycle, including 25 hours in pharmacology.¹⁴ Other certifying bodies set their own rules.

DEA registration renews on a separate three-year cycle. The DEA no longer mails paper renewal notices; email reminders start 60 days before expiration. If you miss the deadline, you have one calendar month to reinstate. After that month, you must apply for a brand-new registration, and you cannot handle any controlled substances during the gap.¹⁵

1
Maryland General Assembly. House Bill 999 Chapter 468 – Nurse Practitioner Full Practice Authority Act of 2015
2
New York Codes, Rules and Regulations. Maryland Health Occupations 8-302.1 – Advanced Practice Certification
3
Board of Nursing – Maryland Department of Health. Criteria for Advanced Practice Certification and Instructions for the Applicant
4
Maryland Department of Health. CDS Application
5
Federal Register. Registration and Reregistration Fees for Controlled Substance and List I Chemical Registrants
6
Maryland General Assembly. Maryland Health Occupations 8-508
7
Centers for Medicare & Medicaid Services. The Who, What, When, Why and How of NPI
8
NPPES. NPI Application Help Page
9
Centers for Medicare & Medicaid Services. PECOS for Physicians and Non-Physician Practitioners
10
Internal Revenue Service. Self-Employment Tax (Social Security and Medicare Taxes)
11
Social Security Administration. Contribution and Benefit Base
12
HHS.gov. Security Rule Guidance Material
13
Maryland Department of Health. Schedule of Fees
14
American Nurses Credentialing Center. ANCC Certification Renewal Handbook
15
Drug Enforcement Administration. Registration