No. Nurse practitioners cannot practice independently in Pennsylvania. Every Certified Registered Nurse Practitioner (CRNP) in the state must have a signed written collaborative agreement with a licensed physician before seeing a single patient, and that requirement is still fully in effect as of 2026. Pennsylvania is one of a shrinking number of states that still requires it.
What the Collaborative Agreement Does
The collaborative agreement is a signed contract between a CRNP and a physician. It spells out what the CRNP is authorized to do, how the two will communicate, and how patient care will be coordinated. Without one, a CRNP has no legal authority to practice in Pennsylvania.1Cornell Law School. Pennsylvania Code 49 Pa. Code 21.282a – CRNP Practice
The physician does not have to be physically present at the CRNP’s office. What the law requires is an ongoing professional relationship with regular communication about patient care. A CRNP can work at a location where no doctor is on-site day to day, but the collaborating physician has to be reachable and actively involved under the terms of the agreement.
Prescribing is governed by a second, related document called a prescriptive authority collaborative agreement. Most CRNPs who prescribe have both in place, and the two work together.
What the Agreement Must Contain
Pennsylvania regulations set out specific elements that a prescriptive authority collaborative agreement has to include. It must identify the collaborating physician, the CRNP, and at least one substitute physician who steps in when the primary collaborator is unavailable. Both the CRNP and the physician must sign it, and it must carry the date it takes effect.2Cornell Law School. Pennsylvania Code 49 Pa. Code 21.285 – Prescriptive Authority Collaborative Agreements
Beyond those identifiers, the agreement must spell out:
- The medical functions the CRNP is authorized to perform, consistent with their specialty certification.
- How the CRNP and physician will communicate about patient care, including how patients get referred to other providers.
- A predetermined plan for handling medical emergencies when the physician is not on-site.
A signed copy has to be kept at the CRNP’s primary practice location and filed with the Bureau of Professional and Occupational Affairs. Anyone can ask to see it, and the CRNP must provide a copy to any licensed pharmacist or pharmacy at no charge. Both parties are required to review and update the agreement at least once every two years, or sooner if something changes. There is no cap on how many CRNPs a single physician can collaborate with.2Cornell Law School. Pennsylvania Code 49 Pa. Code 21.285 – Prescriptive Authority Collaborative Agreements
When an agreement is updated or terminated, the CRNP must notify the State Board of Nursing in writing on the appropriate change form and pay any required fee. This is why the named substitute physician matters. If the primary collaborator retires, moves, or otherwise becomes unavailable, the substitute can provide interim collaboration so the CRNP does not have to stop practicing on the spot. A CRNP who relies on a single physician without a viable backup is taking a real risk with their ability to keep seeing patients.
Prescribing Requires Its Own Approval
A CRNP’s authority to prescribe is not automatic and does not come with the general collaborative agreement. It requires separate Board approval, a prescriptive authority collaborative agreement, and at least 45 hours of advanced pharmacology coursework completed within the five years before applying. The coursework has to go beyond what a registered nurse learns in a standard nursing program.3PA Code and Bulletin. Pennsylvania Code 49 Pa. Code 21.283 – Authority and Qualifications for Prescribing, Dispensing and Ordering Drugs
Within the first year of receiving prescriptive authority, the CRNP must also complete at least two hours of education in pain management or addiction identification and two more hours specifically on prescribing or dispensing opioids.3PA Code and Bulletin. Pennsylvania Code 49 Pa. Code 21.283 – Authority and Qualifications for Prescribing, Dispensing and Ordering Drugs
Pennsylvania also caps supplies on controlled substances written by a CRNP: a 30-day maximum for Schedule II drugs and a 90-day maximum for Schedule III and IV. Those limits have to appear in the prescriptive authority collaborative agreement itself.4Cornell Law School. Pennsylvania Code 49 Pa. Code 21.284 – Prescribing and Dispensing Parameters
What a CRNP Can Do Once the Agreement Is in Place
With a collaborative agreement, a CRNP can perform a wide range of clinical work. Pennsylvania regulations list more than a dozen authorized activities, including:
- Performing comprehensive patient assessments and establishing medical diagnoses
- Ordering, performing, and interpreting diagnostic tests within the CRNP’s specialty
- Developing and implementing treatment plans
- Initiating referrals and consultations with other providers
- Ordering home health, hospice care, and durable medical equipment
- Completing admission and discharge summaries
- Performing disability assessments for public assistance programs
Every activity has to fall within the scope of the agreement and match the CRNP’s national certification specialty. A family nurse practitioner handles general primary care; a psychiatric-mental health NP handles behavioral health. The agreement cannot authorize a CRNP to practice outside their certified specialty, no matter what the physician signs off on. One specific limit: only a physician can order methadone treatment, though a CRNP can perform the initial evaluation.5PA Code and Bulletin. Pennsylvania Code 49 Pa. Code 21.282a – CRNP Practice
Could This Change
There is ongoing legislative interest in giving Pennsylvania nurse practitioners full practice authority. House Bill 739, introduced in the 2025-2026 session, would amend the Professional Nursing Law to expand the CRNP scope of practice and potentially reduce or remove the collaborative agreement requirement.6Pennsylvania General Assembly. House Bill 739 Information
Similar bills have been introduced in past sessions without passing. Physician groups have supported keeping the collaborative agreement requirement, and nursing organizations have opposed it, which has kept the issue among the more contested healthcare policy questions in the state. Until a bill like HB 739 actually passes, the answer stays the same: no independent practice in Pennsylvania, and no patients seen without a signed collaborative agreement on file.