Tennessee collaborative practice agreement requirements depend on who the mid-level provider is: an advanced practice registered nurse (APRN) and a non-endorsed physician assistant (PA) practice under jointly developed protocols with a collaborating physician, while an endorsed PA practices under a collaborative agreement. In every version the document must identify the parties, define scope of practice, spell out prescriptive authority, describe how the physician and provider communicate, and set chart review and site visit obligations. The governing rules sit in Tenn. Code Ann. §§ 63-7-123, 63-7-126, 63-19-106, and 63-19-107, and in Tenn. Comp. R. & Regs. 0880-06-.02.
Which Document You Need
Tennessee treats APRNs and PAs differently, and it further splits PAs into two tracks.
An APRN holding a certificate of fitness under Tenn. Code Ann. § 63-7-123 must file a notice with the Board of Nursing that identifies the collaborating physician and includes a formulary listing the drug categories the APRN will prescribe. The collaborating physician carries control and responsibility for the APRN’s prescriptive services, and the working relationship is governed by jointly developed protocols.1Justia. Tennessee Code 63-7-123 – Certified Nurse Practitioners
A non-endorsed PA practices under protocols jointly developed with a collaborating physician. An endorsed PA, who must have at least 6,000 hours of documented postgraduate clinical experience and board endorsement, instead operates under a collaborative agreement. Endorsement is optional, but the choice matters because chart review, site visit, and oversight duties differ substantially between the two tracks.2Justia. Tennessee Code 63-19-106 – Authorized Services
Whichever document applies, copies must be kept at every practice location in paper or electronic form and produced on request to the relevant licensing board.2Justia. Tennessee Code 63-19-106 – Authorized Services
Physician Qualifications
The collaborating physician must hold an active Tennessee medical license in good standing with the Tennessee Board of Medical Examiners. No statute requires the physician’s specialty to match the APRN’s or PA’s practice area, but the physician must be able to meaningfully oversee the clinical work, and the document should reflect that alignment.
A common misconception is that Tennessee caps a physician at four APRN or PA supervisees. It does not. The Tennessee Board of Medical Examiners has stated there is no prescribed limit; the physician sets the number at the practice level, consistent with good medical practice, so long as chart review and site visit duties can still be met. The one exception is orthopedic physician assistants, where a supervising physician may oversee no more than two at a time.3Tennessee Department of Health. FAQ: Physician Supervision of PAs and APNs
What the Document Must Contain
Minimum content depends on the track. All three versions must be typed, dated, and signed by every party, and every party’s role must be identified. Notarization is not required.
APRN Protocols
Under Tenn. Comp. R. & Regs. 0880-06-.02, APRN protocols must outline the applicable standard of care, be specific to the patient population seen, account for all protocol drugs by formulary, and be reviewed and updated every two years. Each protocol must be dated, signed by both parties, and maintained at every practice site.4Cornell Law School. Tennessee Comp R Regs 0880-06-.02 – Clinical Supervision
Non-Endorsed PA Protocols
Under Tenn. Code Ann. § 63-19-106, non-endorsed PA protocols must describe the PA’s authorized services and practice scope, the collaborating physician’s responsibilities, communication methods, chart review processes, and remote site visit schedules when the PA works at a different location from the physician.2Justia. Tennessee Code 63-19-106 – Authorized Services
Endorsed PA Collaborative Agreements
Endorsed PA agreements carry lighter statutory minimums. The document must specify the PA’s scope of practice, communication methods, and chart review requirements for Schedule II controlled substance and buprenorphine prescriptions. General chart review frequency and site visit schedules are set at the practice level rather than fixed by statute.2Justia. Tennessee Code 63-19-106 – Authorized Services
Provisions to Include in Every Version
Regardless of track, the document should identify each party by name, professional designation, and license number. It should state the physician’s availability for consultation, preferred communication methods, and how disagreements about patient care will be resolved. Both parties should confirm professional liability coverage; Tennessee does not mandate specific amounts.
Scope of practice provisions should distinguish tasks the APRN or PA may perform independently from those requiring direct physician involvement. High-risk procedures, emergency protocols, and any patient-population restrictions belong in writing. Vague language creates liability exposure for both sides. Some invasive procedures carry hard statutory limits. A PA performing spinal injections or blocks of major peripheral nerves outside a licensed facility, for example, must do so under the direct supervision of a physician who actively performs those procedures and holds current hospital privileges for them.5Justia. Tennessee Code 63-19-107 – Practices for Collaboration With Physician Assistants
Chart Review and Site Visits
Oversight rules are where the endorsed and non-endorsed distinction matters most, and getting them wrong is one of the fastest ways to trigger a board investigation.
For APRNs, the collaborating physician must personally review at least 20% of charts written or monitored by the nurse practitioner every 30 days. That is a floor, not a target.4Cornell Law School. Tennessee Comp R Regs 0880-06-.02 – Clinical Supervision
For non-endorsed PAs, the collaborating physician must review at least 20% of charts every 30 days, plus 100% of charts involving a controlled substance prescription within 10 days of issuance. When a non-endorsed PA works at a remote location, the physician must conduct a site visit at least every 30 days.2Justia. Tennessee Code 63-19-106 – Authorized Services
Endorsed PAs are on a different standard. The general chart review schedule is negotiated at the practice level based on the PA’s training, experience, and competence. The statute still mandates 100% chart review within 30 days for Schedule II controlled substance prescriptions and for buprenorphine used in medication-assisted treatment. Two things to notice: the timeframe is 30 days rather than 10, and the trigger is narrower, covering only Schedule II drugs and buprenorphine rather than all controlled substances.2Justia. Tennessee Code 63-19-106 – Authorized Services
Prescriptive Authority
Prescriptive authority is not automatic. It must be spelled out in the protocols or collaborative agreement, and the provider must satisfy additional regulatory requirements before writing prescriptions.
APRNs
Under Tenn. Code Ann. § 63-7-123, an APRN with a certificate of fitness may prescribe controlled substances in Schedules II through V only when the formulary or the collaborating physician specifically authorizes it. For Schedule II, III, and IV drugs, the prescription must either be listed in the formulary filed with the Board of Nursing or expressly approved by the collaborating physician before initial issuance. The formulary is filed as part of the notice to the board, and keeping it current is the APRN’s responsibility.1Justia. Tennessee Code 63-7-123 – Certified Nurse Practitioners The broader authority to diagnose, develop plans of care, and prescribe legend drugs and other treatments comes from Tenn. Code Ann. § 63-7-126.6Justia. Tennessee Code 63-7-126 – Advanced Practice Registered Nurses
PAs
A PA’s prescriptive authority must be delegated by the collaborating physician and set out in protocols or the collaborative agreement. Every PA-issued prescription must be entered in the patient’s medical record, and handwritten prescriptions must be on a preprinted pad bearing the PA’s name, address, and phone number.5Justia. Tennessee Code 63-19-107 – Practices for Collaboration With Physician Assistants
Controlled Substances
Any APRN or PA prescribing controlled substances must register with the U.S. Drug Enforcement Administration and obtain a Tennessee Controlled Substance Registration. Tennessee also requires prescribers to participate in the state’s Controlled Substance Monitoring Database (CSMD). The agreement should reference CSMD compliance and set internal policies for checking the database before issuing controlled substance prescriptions, particularly for opioids and benzodiazepines.
Signatures, Recordkeeping, and Board Access
The document has no legal effect without signatures from every party. Both the APRN or PA and the collaborating physician must sign and date it. When multiple physicians participate, each must sign, and each role must be described. Amendments require fresh signatures and dates.
Copies must be kept at each practice site and produced on request to the Board of Nursing, the Board of Medical Examiners, or the Board of Physician Assistants, whichever is relevant.2Justia. Tennessee Code 63-19-106 – Authorized Services The Tennessee Board of Medical Examiners’ general rules require medical records to be retained for at least 10 years from the last professional contact; while retention specifically for the agreement itself may differ, keeping executed versions at least as long as the underlying patient records is the cautious approach. Digital copies should be stored securely and be easy to retrieve during an audit.
A missing or expired agreement can trigger fines, license suspension, or revocation. Boards routinely request these documents during complaint investigations, and an absent agreement shifts the inquiry from the underlying complaint to a licensing violation on its own.
Updates and Amendments
Tennessee does not set a fixed renewal timeline for the document itself, but APRN protocols must be reviewed and updated at least every two years under Tenn. Comp. R. & Regs. 0880-06-.02.4Cornell Law School. Tennessee Comp R Regs 0880-06-.02 – Clinical Supervision Annual reviews are a sound practice regardless, because they force both parties to reassess scope, prescriptive authority, and oversight against any change in law or clinical experience.
Amendments must be documented in writing and signed by all parties whenever there is a meaningful change: adding procedures, expanding or restricting prescriptive authority, changing communication methods, or altering the oversight structure. If a collaborating physician leaves or becomes unable to serve, the agreement must be updated immediately. Tennessee provides no statutory grace period for practicing without a valid collaboration arrangement, so identifying a backup collaborating physician in advance is a practical safeguard.
When a supervisory relationship ends, the physician or the APRN/PA should revoke the relationship through the CSMD account portal. Leaving it in place keeps controlled substance prescribing authority linked to a physician who no longer oversees the work, creating both regulatory and liability exposure.3Tennessee Department of Health. FAQ: Physician Supervision of PAs and APNs