A collaborating physician agreement in Indiana is the written, signed contract that lets an advanced practice registered nurse (APRN) or physician assistant (PA) treat patients under a licensed physician’s oversight. Indiana Code 25-23-1-19.4 governs APRN practice agreements,1Indiana General Assembly. Indiana Code 25-23-1-19.4 – Advanced Practice Nurse Collaboration With Licensed Practitioner; Privileges; Supervisory Rights and Responsibilities and Indiana Code 25-27.5-6-2 governs PA collaborative agreements, which cap each physician at four simultaneous PA relationships.2Indiana General Assembly. Indiana Code Title 25 – 25-27.5-6-2 The agreement has to be in place before the APRN or PA sees a single patient in the collaborative role.
One boundary worth noting up front: House Bill 1116 was introduced in the 2025 session and would remove the practice-agreement requirement for APRNs. If you are reading this after that session, confirm the bill’s status with the Indiana General Assembly before relying on the APRN requirement described below.
Who the Agreement Covers
Two categories of provider need one. APRNs must operate under a practice agreement with a licensed practitioner before providing patient care services that call for collaboration.1Indiana General Assembly. Indiana Code 25-23-1-19.4 – Advanced Practice Nurse Collaboration With Licensed Practitioner; Privileges; Supervisory Rights and Responsibilities PAs must have a collaborative agreement with at least one physician before practicing.2Indiana General Assembly. Indiana Code Title 25 – 25-27.5-6-2
Who Qualifies as the Collaborating Physician
The physician must hold an active, unrestricted Indiana medical license.3Indiana General Assembly. Indiana Code 25-22.5-5-2 Unrestricted means no pending disciplinary action that would impair the physician’s ability to oversee another provider.
Indiana does not cap the number of APRNs a physician can collaborate with. PAs are different: a physician may have no more than four active PA agreements running at the same time.2Indiana General Assembly. Indiana Code Title 25 – 25-27.5-6-2 A physician can enter into more agreements over time; only four may be simultaneously in force.
The APRN side carries its own qualifications. The APRN must hold a current Indiana nursing license and national specialty certification from a body that administers a national exam.4Legal Information Institute. 848 IAC 4-1-4 – Nurse Practitioner Defined APRNs with prescriptive authority must complete at least 30 continuing education hours per renewal cycle, including 8 hours of pharmacology, with prescriptive authority licenses expiring October 31 of each odd-numbered year.5Indiana Professional Licensing Agency. Nursing Licensing Information PAs must come from an accredited PA program, hold current NCCPA certification, and be licensed through the Indiana Professional Licensing Agency.6Justia. Indiana Code Title 25 Article 27.5 Chapter 4 – Licensure
What the Written Agreement Must Contain
Both parties sign the document, and both update it when practice conditions change. At a minimum, the agreement should spell out:
- Scope of practice: which clinical tasks and procedures the APRN or PA may perform, matched to the provider’s education, training, and certification.
- Prescriptive authority: whether the provider may prescribe, and if so, which drug schedules and any specific restrictions.
- Chart review protocol: for APRNs with prescriptive authority, a written plan to review a five-percent random sample of charts and the medications prescribed, with the review completed within seven days.7Indiana General Assembly. Title 848 Indiana State Board of Nursing Article 5 – Prescriptive Authority for Advanced Practice Nursing
- Consultation and referral methods: how the provider contacts the physician for complex cases, including whether electronic communication is acceptable.
- Any additional limitations the physician imposes beyond what state law requires.
The five-percent, seven-day chart review rule is where many practices stumble. It is not optional, and the deadline is tight enough that both parties need a workflow set up before the first prescription is written. Falling behind here is one of the easiest ways to generate findings during an audit.
For PAs, there is an additional substantive limit: the physician can only delegate tasks that fall within the physician’s own practice.8Indiana General Assembly. Indiana Code 25-27.5-6-3 – Obligations of Physicians and Physician Assistants A cardiologist cannot authorize a PA to perform orthopedic procedures the cardiologist does not perform. Anything the agreement does not explicitly address is off-limits.
Remote Collaboration
Indiana does not require the physician to be physically on-site. The agreement can authorize consultation by phone, video, or secure messaging, which is what makes rural and multi-site practices workable. If telehealth is central to the practice, the agreement should name the specific communication methods and expected response times.
Adding Prescriptive Authority
The agreement is the gateway to prescribing, but it is not the whole process.
An APRN seeking prescriptive authority must complete a graduate-level pharmacology course of at least two semester hours, submit a separate application to the Board of Nursing, and have the practice agreement address prescribing.7Indiana General Assembly. Title 848 Indiana State Board of Nursing Article 5 – Prescriptive Authority for Advanced Practice Nursing APRNs may prescribe legend drugs and controlled substances up to Schedule II, though prescribing opioids for chronic pain triggers extra standards under 848 IAC 5-4. Controlled-substance prescribing requires both an Indiana controlled substances registration and a federal DEA registration.
For PAs, prescriptive authority must be explicitly granted in the collaboration agreement, must sit within the PA’s competence, and must sit within the collaborating physician’s own scope.8Indiana General Assembly. Indiana Code 25-27.5-6-3 – Obligations of Physicians and Physician Assistants Controlled-substance prescribing requires an independent DEA registration using Form 224 for new applicants and Form 224a for renewals.9Diversion Control Division. Registration The DEA sends renewal notices by email, so a current email address on the registration matters.
Filing and Updating the Agreement
Once the agreement is signed, it has to be filed. APRNs file with the Indiana State Board of Nursing; PAs file with the Indiana Professional Licensing Agency. Both filings run through the MyLicense One portal.10Indiana Professional Licensing Agency. PLA Online Services – Change Collaborator Guide
Both parties retain a current copy and produce it on request. Any later change, whether to prescribing authority, scope, or the identity of the collaborating physician, requires an updated agreement to be resubmitted to the board. The physician should also keep records of oversight activity (chart reviews, consultations, performance notes) in enough detail to show compliance if an audit lands.
Ending the Agreement
Both the physician and the advanced practice provider must independently notify the appropriate boards in writing within 15 days of ending the relationship, and the notice must state the reason.11Indiana General Assembly. Title 844 Medical Licensing Board of Indiana For PAs, both the Medical Licensing Board and the PA Committee get the notice. APRNs notify the State Board of Nursing.
The collaborating physician remains responsible for delegated tasks through the termination date in the notice. An APRN or PA who keeps practicing after the agreement ends, without a new one in place, risks disciplinary action up to and including suspension or revocation. Indiana does not mandate a formal patient transition plan, but transferring records, notifying patients in writing, and avoiding lapses in active prescriptions are the practical steps that keep a termination clean.
Liability and Insurance
A collaborating physician can face vicarious liability for an APRN’s or PA’s negligence under respondeat superior, even where the physician’s own oversight was adequate. Before signing, the physician should tell their malpractice carrier about the arrangement. Some carriers add the advanced practice provider as a rider; others require the provider to carry a separate policy. The safest structure is both: a personal policy for the provider and listing on the physician’s policy. Adding a provider can affect the physician’s premium depending on carrier and specialty.
From the APRN or PA side, personal malpractice coverage is strongly advisable regardless of what the physician’s policy says. If the collaboration ends or a claim surfaces afterward, a provider without independent coverage may have no protection.
Compensation and Federal Fraud Rules
Monthly collaboration fees are common in Indiana, and the amount varies with specialty, chart-review volume, and location. Two federal statutes shape how the money can be structured. The Stark Law requires that compensation between referring physicians and the entities they refer to reflect fair market value and not be tied to referral volume or value. The Anti-Kickback Statute, enforced by the Office of Inspector General, prohibits payments intended to induce referrals for federal-program services.
Collaboration fees inflated beyond what the oversight work justifies, or that move with referral patterns, can draw scrutiny under both laws. Professional services arrangements generally fit the personal services safe harbor if the terms are in writing, the compensation is fixed in advance, and the amount reflects genuine fair market value. If any federal-program patients are involved, a compliance review before signing is cheaper than defending an investigation later.
What Happens If You Practice Without a Valid Agreement
Indiana’s licensing boards can fine up to $1,000 per violation, impose probation with practice restrictions, suspend a license, or revoke it, individually or in combination, under Indiana Code 25-1-9-9.12Indiana General Assembly. Indiana Code 25-1-9-9 – Disciplinary Sanctions
The stakes rise sharply from there. An APRN or PA who practices without the required agreement can be treated as practicing medicine without a license, which under Indiana Code 25-22.5-8-2 is a Level 5 felony when done knowingly.13Indiana General Assembly. Indiana Code 25-22.5-8-2 – Offenses A physician who fails to meet oversight obligations faces their own disciplinary track and potential civil liability, particularly where a patient was harmed. Prescribing controlled substances under a noncompliant agreement can also attract a DEA investigation on top of state-level consequences. Board discipline is publicly searchable and follows a provider for the rest of their career, with knock-on effects for credentialing, employment, and malpractice insurance.