Collaborating Physicians in Indiana: Agreement Rules and Filing

Indiana requires a written collaboration agreement between a physician and any advanced practice registered nurse (APRN) or physician assistant (PA) before that provider can treat patients, and the Indiana collaborating physician agreement requirements cover who may sign, what the document must contain, how it must be filed, and how it must be ended. The core rules sit in Indiana Code 25-23-1-19.4 for APRNs¹ and Indiana Code 25-27.5-6-2 for PAs.²

Who Must Have an Agreement

The requirement applies to APRNs providing services that fall within the scope of physician collaboration and to PAs, who by statute practice under a physician’s direction. An APRN must have a practice agreement with a licensed practitioner in place before delivering collaborative patient care.¹ A PA must have a collaborative agreement with at least one physician before practicing.²

Indiana does not cap the number of APRNs a physician may collaborate with. A physician may, however, hold no more than four active PA collaboration agreements at the same time.² A physician can enter into more than four PA agreements overall, but only four may run concurrently.

One pending change is worth flagging. Indiana House Bill 1116, introduced in the 2025 session, would remove the practice agreement requirement for APRNs. Confirm on the Indiana General Assembly’s site whether that bill was enacted before relying on the current rules for long-term planning.

Who Qualifies to Sign

The Collaborating Physician

The physician must hold an active, unrestricted Indiana medical license from the Indiana Medical Licensing Board.³ Unrestricted means no pending disciplinary action that would impair the ability to oversee another provider.

The APRN

An APRN must hold a current Indiana license from the State Board of Nursing and maintain national certification in the specialty through a recognized certifying body that requires a national examination.⁴ APRNs with prescriptive authority must complete at least 30 hours of continuing education before each renewal cycle, including 8 hours in pharmacology; prescriptive authority licenses expire October 31 of each odd-numbered year.⁵

The PA

A PA must graduate from an accredited PA program, pass the Physician Assistant National Certifying Examination (PANCE), maintain current NCCPA certification, and hold licensure through the Indiana Professional Licensing Agency.⁶

What the Written Agreement Must Cover

Both parties must sign the agreement, and it must be updated whenever practice conditions change. At a minimum, the document addresses:

Scope of practice. The medical tasks and procedures the provider may perform, and the conditions under which they may perform them. Delegated tasks must align with the provider’s education, training, and certification. For PAs, the delegated tasks must also fall within the collaborating physician’s own scope of practice. A physician cannot authorize a PA to perform procedures the physician does not perform.⁷
Prescriptive authority. Whether the provider may prescribe, which drug schedules are included, and any specific restrictions.
Chart review protocols. For APRNs with prescriptive authority, the agreement must set out a plan for reviewing prescribing practices, including a five-percent random sampling of charts and medications prescribed, reviewed within seven days. The seven-day turnaround is tight, and both parties need a working system from day one.⁸
Consultation and referral. How the provider reaches the physician for complex cases, including whether electronic communication is acceptable. Indiana does not require the physician to be physically on-site at all times; the agreement can allow consultation by phone, video, or secure messaging.
Additional limitations. Any restrictions the physician places on the provider’s authority beyond state law.

Anything not addressed in the agreement is off-limits. The written document defines the ceiling of what the provider may do.

Prescriptive Authority Add-Ons

Indiana lets both APRNs and PAs prescribe medications, including controlled substances, but only when the agreement grants that authority and the provider meets separate requirements.

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 a signed practice agreement that addresses prescribing.⁸ APRNs may prescribe legend drugs and controlled substances, including Schedule II, though prescribing opioids for chronic pain triggers additional standards under 848 IAC 5-4.

PA prescriptive authority must be explicitly granted in the collaboration agreement, and delegated prescribing must fall within both the PA’s competence and the physician’s own scope of practice.⁷

For any controlled substance, both APRNs and PAs need an Indiana controlled substances registration and a federal DEA registration. State authority alone does not cover it. New DEA applicants file Form 224; renewals use Form 224a.⁹

Filing and Updating the Agreement

Once the agreement is signed, the provider files it with the appropriate board. 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.¹⁰

Both parties must keep a current copy available for inspection. Any change to prescribing authority, scope of services, or the collaborating physician’s identity requires an updated agreement, resubmitted to the relevant board. The physician should also keep records of oversight activities, including chart reviews and consultations, in enough detail to demonstrate compliance during an audit.

Ending the Agreement

When the collaborative relationship ends, both the physician and the advanced practice provider must independently notify the appropriate boards, in writing, within 15 days, stating the reason for termination.¹¹ For PAs, both the Medical Licensing Board and the PA Committee must receive notice. For APRNs, notice goes to the State Board of Nursing.

The physician remains responsible for delegated tasks until the termination date stated in the notice. An APRN or PA who continues to practice after the agreement ends without securing a replacement risks disciplinary action, including license suspension or revocation. Missing the 15-day deadline can delay the provider’s ability to establish a new collaboration.

Penalties for Noncompliance

Under Indiana Code 25-1-9-9, disciplinary measures include fines of up to $1,000 per violation, probation with practice restrictions, license suspension, and permanent revocation, imposed individually or in combination.¹²

Practicing without a required agreement carries heavier exposure. An APRN or PA working in a role that requires collaboration but has none in place may be treated as practicing medicine without a license, which is a Level 5 felony under Indiana Code 25-22.5-8-2 when done knowingly.¹³ Prescribing controlled substances under a noncompliant agreement can also draw a DEA investigation on top of state discipline. Board actions are publicly accessible and follow the provider through future credentialing, employment, and malpractice underwriting.

1
Indiana General Assembly. Indiana Code 25-23-1-19.4 – Advanced Practice Nurse Collaboration With Licensed Practitioner; Privileges; Supervisory Rights and Responsibilities
2
Indiana General Assembly. Indiana Code Title 25 – 25-27.5-6-2
3
Indiana General Assembly. Indiana Code 25-22.5-5-2
4
Legal Information Institute. 848 IAC 4-1-4 – Nurse Practitioner Defined
5
Indiana Professional Licensing Agency. Nursing Licensing Information
6
Justia. Indiana Code Title 25 Article 27.5 Chapter 4 – Licensure
7
Indiana General Assembly. Indiana Code 25-27.5-6-3 – Obligations of Physicians and Physician Assistants
8
Indiana General Assembly. Title 848 Indiana State Board of Nursing Article 5 – Prescriptive Authority for Advanced Practice Nursing
9
Diversion Control Division. Registration
10
Indiana Professional Licensing Agency. PLA Online Services – Change Collaborator Guide
11
Indiana General Assembly. Title 844 Medical Licensing Board of Indiana
12
Indiana General Assembly. Indiana Code 25-1-9-9 – Disciplinary Sanctions
13
Indiana General Assembly. Indiana Code 25-22.5-8-2 – Offenses