Utah collaborating physician requirements differ significantly from most other states because of a landmark change that took effect in 2023. Utah is a full practice authority state for nurse practitioners. Senate Bill 36, signed by Governor Spencer Cox on March 16, 2023, eliminated the state-mandated contract with a physician that NPs previously required as a condition of licensure. Utah became the 27th state to adopt full practice authority for NPs, and the physician collaboration requirement for nurse practitioners no longer exists under Utah law.
For physicians exploring collaboration roles in Utah, the active compliance framework centers on physician assistants. PAs in Utah operate under a tiered experience model governed by Utah Code § 58-70a-307. The structure requires physician collaboration during defined periods of a PA’s career and permits independent practice once a PA reaches the 10,000-hour experience threshold. This guide covers every requirement a physician needs to understand before entering any Utah collaboration arrangement in 2026.
Utah Collaborating Physician Overview: Where Utah Stands
Utah’s transition to full NP practice authority in 2023 was one of the most significant scope-of-practice changes in recent state history. Prior to SB 36, Utah Code § 58-31b-803 limited NPs in their prescriptive authority, including for Schedule II controlled substances, and required a state-mandated physician contract as a condition of licensure. That entire framework was repealed. Utah NPs now practice under the full extent of their training and licensure with no physician oversight requirement of any kind.
For physician assistants, the framework is more structured. The Utah Division of Professional Licensing (DOPL) governs PA licensure, collaboration requirements, and disciplinary matters under Utah Code § 58-70a and Administrative Code Rule R156-70a.
Utah’s Position Nationally
Utah is one of five states that allows PAs to transition from a collaborative framework to independent practice after accumulating sufficient post-graduate clinical experience. Among those five states, Utah requires the most time in collaboration before independent practice is permitted.
NP Practice Authority in Utah: What Full Practice Means for Physicians
Because Utah NPs do not require physician agreements by law, the traditional model of a physician delegating prescriptive authority to an NP does not apply in this state. NP-operated clinics in Utah are legally compliant without any physician involvement at the oversight level. Utah NPs may diagnose, treat, prescribe, and manage patient care across all four elements of advanced nursing practice without restriction.
Physicians entering Utah collaboration arrangements should focus entirely on PA-based frameworks. There is no statutory NP collaboration pathway in Utah, and no board-filed NP agreement structure exists.
Some health systems and credentialing bodies may maintain internal policies requiring physician involvement for NPs even beyond what state law requires. These are contractual and institutional arrangements rather than statutory requirements.
Where Physician Collaboration Still Applies in Utah
Active physician collaboration requirements in Utah apply in two contexts:
- Physician assistant collaboration. Every PA with fewer than 10,000 hours of post-graduate clinical practice experience must operate within a defined collaboration structure with a physician. The specific obligations depend on where the PA falls within the three-tier experience model.
- Associate physician collaborative practice arrangements. Utah recognizes a category of associate physician, defined as a graduate of a medical school who has not completed a residency program. Associate physicians may provide care under a collaborative practice arrangement with a supervising physician that must be approved by DOPL before practice begins.
For most outpatient clinic contexts, the PA collaboration framework is the primary statutory structure that brings physicians into a Utah compliance relationship. This guide addresses both, with primary focus on the PA model.
The PA Collaboration Framework: Utah’s Three-Tier Model
Utah Code § 58-70a-307 creates three distinct tiers of practice authority for PAs based on post-graduate clinical hours. Physicians entering Utah collaboration arrangements must understand which tier applies to the PA and structure their involvement accordingly.
Tier 1: Direct Collaboration (Under 4,000 Hours)
A PA with fewer than 4,000 hours of post-graduate clinical practice experience must engage in direct collaboration with a physician for the full period until reaching 4,000 hours. During this period, the PA must practice under written policies and procedures established at the practice level that describe how collaboration will occur and describe methods for evaluating the PA’s competency, knowledge, and skills. There is no formal written collaborative agreement required at this tier, but the written policies and procedures must be available for board review on request. The physician providing collaboration at this stage bears active responsibility for direction and guidance during the PA’s foundational practice period.
Tier 2: Written Collaborative Agreement (4,000 to Under 10,000 Hours)
A PA with more than 4,000 hours and fewer than 10,000 hours of post-graduate clinical practice experience must enter into a written collaborative agreement with either a licensed physician or a licensed PA who has more than 10,000 hours of practice experience in the same specialty. This is the tier where the physician’s formal written collaboration obligation applies in its clearest form.
The written collaborative agreement must describe how collaboration under the statute and relevant administrative code subsections will occur. It must be kept on file at the PA’s practice location and be provided to the board upon request.
Tier 3: Independent Practice (10,000 or More Hours)
A PA with 10,000 or more hours of post-graduate clinical practice experience may practice independently without any physician collaboration or agreement requirement. This is a unique feature of Utah’s framework not found in most states.
Specialty Change Rule
A PA who wishes to change specialties to another specialty in which the PA has fewer than 4,000 hours of experience must engage in collaboration with a physician trained and experienced in the new specialty for a minimum of 4,000 hours before transitioning to a standard Tier 2 arrangement in that specialty.
What Must Be in a Utah PA Collaborative Agreement
Under Utah Code § 58-70a-307(3)(b), a written collaborative agreement for a Tier 2 PA must:
1. Description of Collaboration
The agreement must describe how collaboration under Utah Code § 58-70a-307 and the relevant administrative code subsections will occur. The statute defines collaboration as the interaction and relationship the PA has with one or more physicians in which the PA and physician are cognizant of the PA’s qualifications and limitations, the PA consults with the physician regarding patient care, and the physician gives direction and guidance to the PA.
2. On-Site Retention
The agreement must be kept on file at the PA’s practice location. Unlike some states, Utah does not require the agreement to be filed with a state board. It is retained at the practice and produced to the DOPL upon request.
3. Board Production on Request
The PA must provide the collaborative agreement to the board upon the board’s request. Agreements that are not current, specific, or accurately reflecting the actual collaboration create a compliance problem the moment the board reviews the file.
Physician Eligibility and the Collaboration Standard
A Utah collaborating physician must hold a current, active Utah medical license. The physician must be trained and experienced in a specialty relevant to the PA’s practice area, particularly when the PA is in Tier 1 or transitioning specialties.
Collaboration Defined
Under Utah Code § 58-70a-307(1), collaboration means the interaction and relationship a PA has with one or more physicians in which:
- The PA and physician are both aware of the PA’s qualifications and limitations in caring for patients
- The PA, while responsible for the care they provide, consults with the physician regarding patient care
- The physician gives direction and guidance to the PA
This is a substantive standard. A physician who signs a collaborative agreement but provides no real consultation or guidance is not meeting the statutory definition regardless of the document’s existence.
Immediate Consultation Requirement
Under Utah Administrative Code R156-70a-501, there must be a method of immediate consultation by electronic means whenever the PA is not under the direct supervision of the supervising physician. The physician and PA must review sufficient practice information, which may include patient charts and medical records, to ensure patient health, safety, and welfare are not compromised.
Prescriptive Authority in Utah
For NPs
Utah NPs with full practice authority may prescribe any medication, including Schedule II through V controlled substances, without restriction and without any physician involvement. The prior Schedule II limitation tied to the physician contract requirement was eliminated by SB 36.
For PAs
PAs in Utah may prescribe medications within the scope of their collaborative agreement and consistent with state and federal law. A PA’s prescriptive authority in the collaborative tier is shaped by the terms of the agreement and the physician’s own scope of practice. PAs prescribing controlled substances must hold a valid Utah Controlled Substance License and a federal DEA registration.
The Associate Physician Collaborative Practice Arrangement
Utah recognizes a distinct category of provider called an associate physician: a graduate of an accredited medical school who has not completed a residency program. Under Utah Administrative Code R156-67-807 and Utah Code § 58-67-807, an associate physician may provide health care services under an approved collaborative practice arrangement with a collaborating physician.
Key Requirements for Associate Physician Arrangements
- Both parties must sign a written collaborative practice arrangement contract before practice begins
- The contract must be submitted to the DOPL for written approval before the associate physician provides any care
- The contract must include the scope of medical services the associate physician will provide, the collaborating physician’s oversight plan, an educational plan that facilitates the associate physician’s development throughout the arrangement, and remedies in the event of a breach including termination procedures
- The DOPL evaluates whether the contract sufficiently protects public health, safety, and welfare before granting approval
- The collaborating physician must ensure both parties are appropriately licensed and practicing pursuant to a DOPL-approved contract
The associate physician framework is governed separately from the PA collaboration framework and involves a more formal state approval process.
The 2026 Legislative Update: What SB 31 Changes
Utah Senate Bill 31, in its third substitute form, was introduced in the 2026 general session and proposes to reduce the number of hours a PA must work in collaboration before becoming eligible for independent practice from 10,000 to 8,000 hours.
This change, if enacted, would affect the timeline for Tier 2 to Tier 3 progression for PAs currently in collaborative arrangements. Physicians with active written collaborative agreements with experienced PAs should monitor the status of SB 31, as its passage would move some PAs into independent practice eligibility earlier than currently expected.
The bill also proposes to clarify regulations for ketamine and IV hydration clinics, which have become a growing area of practice in Utah where the regulatory framework for both NPs and PAs has created compliance questions.
Common Compliance Mistakes Utah Collaborating Physicians Make
Most Utah PA collaboration compliance problems involve documentation gaps, tier misidentification, and failure to update the agreement when the PA’s hours status changes.
- Treating a Tier 2 PA as Tier 1 or Tier 3. The obligations differ significantly across tiers. A physician who is providing Tier 1 direct collaboration without documenting it, or who has signed a Tier 2 formal agreement for a PA who has now crossed 10,000 hours, is operating under an arrangement that no longer matches the PA’s actual status.
- Written policies not in place for Tier 1 PAs. Tier 1 PAs must practice under written policies and procedures describing how collaboration occurs and how the PA’s competency is evaluated. A physician who collaborates with a sub-4,000-hour PA without any written practice-level policies has no documentation to produce if the DOPL requests review.
- Collaborative agreement not on file at the practice location. The Tier 2 agreement must be kept at the PA’s practice location and produced to the board on request. Agreements stored elsewhere or only retained by the physician create a compliance gap.
- Specialty change not addressed. When a PA changes specialties, a fresh 4,000-hour collaboration period in the new specialty is required if the PA has fewer than 4,000 hours in that specialty. A physician who continues an existing arrangement when the PA shifts clinical focus without updating the oversight structure is not meeting the specialty change requirement.
- Associate physician arrangements not pre-approved by DOPL. Associate physicians cannot see patients under a collaborative arrangement until the DOPL has reviewed and issued written approval of the collaborative practice contract. Arrangements that begin before approval is received are noncompliant from the first patient encounter.
Utah Collaborating Physician Requirements: Quick Reference
NP Practice Authority
- Utah is a full practice authority state for NPs effective March 2023 (SB 36)
- No physician collaboration, agreement, or supervision required for NP practice or prescribing
- No board filing, transition period, or prior approval required for Utah NPs
PA Collaboration Tiers
- Tier 1 (under 4,000 hours): direct physician collaboration required; written practice-level policies and procedures maintained; no formal written agreement required
- Tier 2 (4,000 to under 10,000 hours): written collaborative agreement with a physician or experienced PA required; kept on file at practice location
- Tier 3 (10,000 or more hours): independent practice; no collaboration or agreement required
- Specialty change: 4,000 hours of collaboration in new specialty required if PA has under 4,000 hours in that specialty
Written Collaborative Agreement (Tier 2)
- Must describe how collaboration will occur per Utah Code § 58-70a-307
- Kept on file at the PA’s practice location
- Produced to DOPL upon request; not submitted to a state board
Physician Eligibility
- Active Utah MD or DO license
- Trained and experienced in a specialty relevant to the PA’s practice area
- Must provide real consultation and direction, not merely sign an agreement
Immediate Consultation
- Method of immediate electronic consultation required when PA is not directly supervised
Associate Physician Arrangements
- Written contract required and submitted to DOPL for approval before practice begins
- Must include scope of services, oversight plan, educational plan, and breach remedies
2026 Legislative Update
- SB 31 proposes reducing PA collaboration hours from 10,000 to 8,000 for independent practice eligibility
Clinics Also Need to Understand Utah Collaboration Requirements
While this guide primarily covers the responsibilities and compliance requirements placed on collaborating physicians in Utah, these regulations directly affect PA-operated clinics and healthcare practices that depend on physician collaboration during the PA’s early career period. In many cases, clinic owners researching Utah collaboration rules are also trying to understand which tier their PA falls into and how to structure a compliant physician relationship that matches the PA’s actual experience level.
Need Help Finding a Utah Collaborating Physician?
For clinics, understanding the legal requirements is only one part of the process. The next challenge is finding a qualified physician who understands Utah’s three-tier PA model, is willing to provide genuine consultation and direction as required by statute, and whose specialty background aligns with the PA’s practice area. Whether you are launching a new clinic with a Tier 1 PA who needs active physician collaboration during the first 4,000 hours, or managing a Tier 2 arrangement that requires a written agreement, having the right physician in place from the start is essential.
If your clinic is actively looking for a Utah collaborating physician, our team can match you with a qualified physician, often within 24 to 48 hours. We work with clinics across Utah to simplify the physician matching process while supporting onboarding, agreement documentation, and long-term collaboration needs.
Final Thoughts
Utah collaborating physician requirements reflect a state that has moved to the leading edge of provider autonomy for NPs while maintaining a structured, experience-based oversight model for PAs. The NP physician collaboration requirement is gone entirely. What remains is a tiered PA framework that requires genuine physician involvement during defined periods of a PA’s career, with a clear pathway to full independent practice once the experience threshold is met.
For physicians entering the Utah PA collaboration market, the key is identifying which tier applies to the specific PA, ensuring the correct level of documentation is in place for that tier, and updating the arrangement when the PA’s hours status changes. A collaboration that was correctly structured at the start can drift out of compliance as the PA’s experience evolves.
Build a Compliant Utah Collaboration With Collaborating Physician
Are you looking for a collaborating physician role in Utah? If you are a licensed Utah physician interested in a structured, compliant collaboration arrangement with a PA-operated clinic, Collaborating Physician handles the infrastructure so you do not have to figure it out alone. The platform connects licensed physicians with vetted clinics across Utah and 50-plus other states. Every arrangement is built to meet state-specific requirements, including Utah’s three-tier PA collaboration framework under Utah Code § 58-70a-307, immediate consultation obligations, specialty alignment standards, and written agreement requirements for Tier 2 PAs. Physicians receive compliance support throughout the collaboration, not just at the start. Applications take under ten minutes. Clinic matches typically happen within 24 to 48 hours. There is no cost to physicians at any stage.
If you are a clinic owner who found this page, we have something for you as well. Collaborating Physician also matches Utah clinics with qualified, vetted collaborating physicians who understand the state’s PA experience tiers and are ready to provide the right level of collaboration for where your PA currently stands. Whether you are opening a new clinic with a Tier 1 PA, managing an existing Tier 2 arrangement, or planning for a PA’s specialty transition, the network is active and placements happen within 24 to 48 hours. For clinics looking for a collaborating physician, get matched fast.
Disclaimer: This content is for educational and informational purposes only. It does not constitute legal or medical advice. Utah healthcare regulations change frequently, and SB 31 introduced in the 2026 general session may materially affect PA collaboration hour thresholds. Always verify current requirements directly with the Utah Division of Professional Licensing and a qualified healthcare attorney before making any practice decisions.
Frequently Asked Questions
Does a Utah physician need to collaborate with nurse practitioners?
No. Utah has been a full practice authority state for NPs since March 2023 following the signing of Senate Bill 36. The state-mandated physician contract previously required as a condition of NP licensure was eliminated entirely. Utah NPs may practice, prescribe, and manage patient care independently without any physician agreement or oversight.
When does a Utah PA no longer need a collaborating physician?
A PA with 10,000 or more hours of post-graduate clinical practice experience may practice independently in Utah with no collaboration or written agreement requirement. Utah is one of five states that allows this transition to full PA independent practice.
What is the difference between Tier 1 and Tier 2 PA collaboration in Utah?
Tier 1 applies to PAs with fewer than 4,000 hours of experience. It requires direct physician collaboration and written practice-level policies describing how collaboration occurs, but does not require a formal written collaborative agreement. Tier 2 applies to PAs with 4,000 to under 10,000 hours. It requires a formal written collaborative agreement kept on file at the practice location.
Does a Utah PA collaborative agreement need to be filed with the state?
No. The written collaborative agreement for a Tier 2 PA must be kept on file at the PA’s practice location and produced to the DOPL upon request. It is not submitted to the state before practice begins.
What happens when a Utah PA changes specialties?
A PA changing to a specialty in which they have fewer than 4,000 hours of experience must engage in collaboration with a physician trained and experienced in the new specialty for a minimum of 4,000 hours before operating under a standard Tier 2 arrangement in that specialty. The collaborative agreement must reflect this specialty-specific requirement.
What is an associate physician collaborative practice arrangement in Utah?
An associate physician is a medical school graduate who has not completed a residency program. Associate physicians may provide health care services under a collaborative practice arrangement with a supervising physician under Utah Code § 58-67-807. Both parties must sign a written contract, submit it to the DOPL for approval, and receive written approval before any patient care begins.
