Full Practice Authority in Illinois: APRN Rules and Prescribing

An advanced practice registered nurse in Illinois can practice independently — diagnosing, treating, and prescribing without a collaborative agreement with a physician — once she completes 4,000 hours of clinical experience and 250 hours of continuing education after national certification, and files a notarized attestation with the Illinois Department of Financial and Professional Regulation. This is what full practice authority for an Illinois APRN means under Section 65-43 of the Nurse Practice Act, added by Public Act 100-0513.¹² Once granted, it lets you open your own practice, bill insurers directly, and manage patients without physician oversight.

Which APRNs Can Get It

Full practice authority is available to three of the four APRN roles: nurse practitioners, clinical nurse specialists, and certified nurse midwives.¹ Certified registered nurse anesthetists are not covered by Section 65-43 and still practice under collaborative agreements in Illinois. Legislation to extend the authority to CRNAs has been introduced but, as of early 2026, has not been enacted.

The Three Requirements

Qualifying comes down to three thresholds, all verified through the IDFPR:

At least 4,000 hours of clinical practice in your area of certification, completed after you first attained national certification. The hours must have been worked in collaboration with a physician, and completion must be attested to by the collaborating physician or your employer.
At least 250 hours of continuing education or training in your certified specialty area.
Current national certification from an accredited board, such as the American Academy of Nurse Practitioners Certification Board.³

When you meet all three, you file a notarized attestation with the IDFPR. No new license category is issued. The attestation lifts the collaborative agreement requirement from your existing APRN license.¹ The IDFPR can ask for documentation of your clinical hours and continuing education at any point, so keep detailed records from your collaborating physicians and any training programs.

What You Can Do

Once your attestation is on file, you can independently provide the full range of services consistent with your national certification: assessments, diagnosis, treatment planning, ordering and interpreting diagnostic tests, and health education.⁴ Practice settings are not restricted.

Built into the statute is a duty to recognize the limits of your own knowledge and refer patients when a situation exceeds your expertise. You are fully accountable to patients for the quality of the care you deliver, in the same way a physician would be.

Prescribing Under Full Practice Authority

Prescribing is where the change from collaborative practice is most concrete. You can independently prescribe legend drugs and Schedule II through V controlled substances.¹ Two categories carry extra rules.

Schedule II Narcotics

You can prescribe Schedule II narcotics such as opioids, but only within a consultation relationship with a physician. This is not a collaborative agreement. Both you and the physician record the relationship in the Prescription Monitoring Program. The specific narcotic must be identified by brand or generic name, and delivery is limited to oral, topical, or transdermal forms.¹ Under a collaborative agreement, Schedule II prescriptions were capped at a 30-day supply and required monthly case discussions with the delegating physician.⁵

Benzodiazepines

As of January 1, 2024, you can prescribe up to a 120-day supply of benzodiazepines without a physician consultation. Anything beyond 120 days triggers the same consultation process as opioids.

Controlled Substance Registration

Any controlled substance prescribing requires both an Illinois controlled substance license and a federal DEA registration. The DEA classifies NPs, nurse midwives, CRNAs, and CNSs as “mid-level practitioners” for registration.⁶ Registration runs three years for $888.⁷ The IDFPR handles the state-level mid-level practitioner license.⁸

Telehealth

The Illinois Telehealth Act lets APRNs deliver care by telehealth to patients located in Illinois, so long as you hold an Illinois license and stay within your scope of practice. The statute is explicit that telehealth neither expands nor restricts scope beyond what you can do in person. Prescribing included.

For Medicare patients, telehealth is available from any location in the United States through December 31, 2027, with no geographic restrictions on the patient.⁹ If you plan to see patients located outside Illinois, you need licensure in the patient’s state. Illinois licensure alone does not authorize treating patients elsewhere.

Getting Paid

Reimbursement rules split three ways.

Medicare pays nurse practitioners at 85% of the physician fee schedule when they bill independently under their own NPI.¹⁰ The alternative is “incident to” billing at the full physician rate, which requires that the supervising practitioner personally performed the initial service, remain actively involved in treatment, and provide direct supervision.¹¹

Illinois Medicaid pays certified nurse practitioners and clinical nurse specialists at 100% of the physician rate for all services except psychiatric services, which must be rendered by a physician. APRNs can also enroll as primary care providers under the Maternal and Child Health program.¹²

Private insurer policies vary. Because the amended Nurse Practice Act recognizes APRNs as independent providers, most commercial plans in Illinois credential and reimburse them directly. Credentialing typically takes several months, so start applications well before your target opening date.

Opening an Independent Practice

Full practice authority is a clinical license, not a business license. If you are going solo, several administrative pieces sit outside the IDFPR attestation.

You need a federal Employer Identification Number from the IRS if your practice has employees, uses a business name, or is organized as an LLC, corporation, or partnership. Sole proprietors using their own name with no employees can skip it, though most banks require one to open a business account. There is no fee.

You need an individual (Type 1) National Provider Identifier through NPPES. The application asks for at least one taxonomy code, a practice location, and your state license information.¹³ There is no fee, and the NPI stays valid indefinitely as long as your enrollment stays current.

If you plan to run any in-office lab tests, including basic point-of-care work like rapid strep or glucose, you need a CLIA waiver. The application uses CMS Form 116, is submitted to the state agency, and takes two to four weeks. The waiver renews every two years. Practices that only draw blood and send specimens to an outside lab do not need a CLIA certificate.

Malpractice insurance is not legally required for APRNs in Illinois, but operating without it exposes you to serious financial risk, and most hospital and insurer credentialing packets require proof of coverage. Annual premiums for independent nurse practitioners generally fall between $700 and $1,400 depending on specialty, claims history, and limits.

An independent APRN is a HIPAA covered entity in her own right. That means maintaining a Notice of Privacy Practices, putting security safeguards in place for electronic records, and training staff on privacy obligations. Recent federal updates aligned substance use disorder confidentiality rules with HIPAA, expanding notice obligations for any practice handling behavioral health or addiction records. If you were previously working under a physician’s HIPAA infrastructure, you build your own from scratch.

Keeping the Authority

The IDFPR processes attestations, verifies clinical hours and continuing education, and monitors ongoing compliance. You must keep your national certification current and continue meeting continuing education requirements to hold the authority.

Noncompliance can bring reprimands, fines, license suspension, or revocation. The agency also coordinates with state and federal partners on controlled substance compliance, including Prescription Monitoring Program reporting for Schedule II narcotic consultation relationships.¹

1
Illinois General Assembly. Illinois Code 225 ILCS 65/65-43 – Full Practice Authority
2
Illinois General Assembly. Bill Status of HB 313
3
American Academy of Nurse Practitioners Certification Board. Welcome to the American Academy of Nurse Practitioners Certification Board
4
Illinois General Assembly. Illinois Code 225 ILCS 65 – Nurse Practice Act
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Illinois General Assembly. Illinois Code 225 ILCS 65/65-40 – Prescriptive Authority
6
Diversion Control Division (DEA). Mid-Level Practitioners Authorization by State
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Federal Register. Registration and Reregistration Fees for Controlled Substance and List I Chemical Registrants
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Illinois General Assembly. Illinois Code 720 ILCS 570/303.05 – Mid-Level Practitioner Registration
9
Centers for Medicare & Medicaid Services. Telehealth FAQ
10
Centers for Medicare & Medicaid Services. Advanced Practice Registered Nurses (APRNs)
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Centers for Medicare & Medicaid Services. Incident To Services and Supplies
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Illinois Department of Healthcare and Family Services. Individual Practitioner
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NPPES. NPI Application Help