Tennessee collaborating physician requirements apply to a restricted-practice state with some of the most operationally specific ongoing oversight obligations in the country. Tennessee does not grant nurse practitioners full practice authority. Every APRN who performs acts of medical diagnosis, develops a medical plan of care, or prescribes medications must hold a certificate of fitness issued by the Tennessee Board of Nursing and must practice under the supervision of a collaborating physician. That requirement has no expiration and applies for the full duration of the APRN’s career.
For physicians entering collaboration roles in Tennessee, the compliance obligations go far beyond signing a document. Tennessee requires monthly site visits to remote practice locations, a mandatory 20% chart review every 30 days, protocol updates on a biennial cycle, and physical presence or availability for consultation at all times. Getting each of these right and maintaining documentation of each obligation is what determines whether a Tennessee collaboration is defensible under regulatory scrutiny. This guide covers every requirement a physician needs to understand in 2026.
Tennessee Collaborating Physician Overview: Where Tennessee Stands
Tennessee classifies APRNs in the restricted-practice category with no independence pathway. There is no experience threshold, no hours accumulation route, and no application process through which an APRN can eventually practice without a collaborating physician. The requirement is permanent.
Governing Bodies
Two regulatory bodies jointly govern APRN-physician collaboration arrangements in Tennessee:
- Tennessee Board of Nursing (TBON): Governs APRN licensure, certificate of fitness requirements, CPA standards, and APRN prescriptive authority under TCA § 63-7-123 and Tenn. Comp. R. and Regs. 1000-04.
- Tennessee Board of Medical Examiners (TBOME): Governs physician licensure, clinical supervision requirements, the 20% monthly chart review standard, the monthly site visit mandate, and disciplinary oversight of physicians in collaborative arrangements under Tenn. Comp. R. and Regs. 0880-06.
Both boards jointly adopted the clinical supervision rules that define the physician’s ongoing obligations. Compliance failures on the physician side are investigated by the TBOME, and failures on the APRN side are investigated by the TBON.
The Certificate of Fitness
Tennessee uses the term certificate of fitness rather than prescriptive authority certificate. Under TCA § 63-7-123, an active certificate of fitness issued by the TBON authorizes an APRN to perform acts of medical diagnosis, develop a medical plan of care and therapeutics for a patient, prescribe or issue legend drugs, and prescribe other treatments. The certificate of fitness requires both an active APRN certification and a valid collaborative practice agreement in place with a qualified physician.
The Collaborative Practice Agreement: Tennessee’s Core Compliance Document
Tennessee requires a written collaborative practice agreement between the APRN and the collaborating physician. Under Tenn. Comp. R. and Regs. 0880-06-.02, the CPA must be kept at the APRN’s practice site, signed and dated by both the physician and the APRN.
The agreement is not filed with either board before practice begins. However, both the TBON and the TBOME may request the CPA at any time, and the document must be available at the practice site.
The Biennial Protocol Update
Under Tenn. Comp. R. and Regs. 0880-06-.02, written protocols included in or referenced by the CPA must be signed and updated every two years. The two-year update cycle applies to the protocols themselves, not just to the master agreement. Protocols that have passed the two-year mark without a signed update are out of compliance regardless of how specific and appropriate they were when originally drafted.
What Must Be in a Tennessee CPA
Tennessee regulations and the joint TBOME-TBON rules specify the required content of a valid collaborative practice agreement. The agreement must address all of the following:
1. Party Identification and License Information
The CPA must identify both the APRN and the collaborating physician by full legal name, professional designation, and license number.
2. Scope of Practice and Written Protocols
The agreement must include written protocols specific to the practice area and patient population served. The protocols must identify the drugs the APRN is authorized to prescribe and the expected standard of care within the APRN’s certification category.
3. Physician Availability and Substitute Physician Provisions
The CPA must establish that the supervising physician will be available for consultation at all times, either personally or through a designated substitute physician. Tenn. Comp. R. and Regs. 0880-06-.02 is explicit: supervision does not require the continuous and constant presence of the supervising physician, but the physician must be available for consultation at all times or shall make arrangements for a substitute physician to be available.
4. Chart Review Process
The CPA must specify the physician’s chart review obligations. Under Tenn. Comp. R. and Regs. 0880-06-.02(8), the supervising physician must personally review at least 20% of charts monitored or written by the APRN every 30 days. This is a mandatory minimum that must be described and documented in the agreement.
5. Site Visit Schedule
The agreement must address the physician’s obligation to visit the APRN’s remote practice site. Under Tenn. Comp. R. and Regs. 0880-06-.02(9), the supervising physician is required to visit any remote site at least once every 30 days. This is not optional or discretionary. It applies to every location where the APRN practices that is separate from the physician’s primary location.
6. Prescriptive Authority Parameters
The CPA must detail which drug categories the APRN is permitted to prescribe, including any restrictions on controlled substances. Prescriptive authority must be explicitly delegated by the physician in the written agreement. The APRN has no prescriptive authority beyond what is expressly stated in the CPA.
7. Malpractice Coverage
Under Tennessee requirements, liability and malpractice coverage must be addressed in the CPA. Both parties should carry appropriate professional liability coverage, and the agreement should reflect each party’s coverage status.
Physician Eligibility and the Same-Field Expertise Standard
A Tennessee collaborating physician must hold a current, unencumbered license to practice medicine or osteopathic medicine in Tennessee. Under Tenn. Comp. R. and Regs. 0880-06-.02(1), both the supervising physician and any substitute supervising physician must possess a current, unencumbered license to practice in the state.
The Same-Field Expertise Standard
Under Tenn. Comp. R. and Regs. 0880-06-.02(3), a supervising physician and any substitute supervising physician must have experience and expertise in the same area of medicine as the APRN. This standard is defined expansively. It encompasses the range of services routinely provided in the course of the physician’s medical practice and may also include services not routinely provided but regarding which the physician has specific, current, reliable knowledge acquired during medical training.
Tennessee does not require an exact specialty match, but the physician’s clinical background must produce genuine capability to supervise the APRN’s practice. A physician who reviews charts, conducts monthly site visits, and provides monthly consultation on clinical areas outside their own experience and knowledge is not meeting the expertise standard.
No Geographic Proximity Requirement
Tennessee does not impose a geographic proximity requirement on collaborating physicians. The physician is not required to maintain a practice location within a defined distance of the APRN’s clinic. What Tennessee does require is that the physician visit every remote site at least once every 30 days. The absence of a distance rule does not eliminate the visit obligation.
No Ratio Limit
Tennessee does not prescribe a fixed number of APRNs a physician may supervise. Under TBOME FAQ guidance, the number of PAs and APRNs a physician may supervise should be determined by the physician at the practice level, consistent with good medical practice. The physician must be able to fulfill the 20% monthly chart review obligation and the monthly site visit requirement for every active APRN under their supervision.
The Monthly Site Visit Requirement
Tennessee’s mandatory monthly site visit is one of the most distinctive ongoing obligations for collaborating physicians in the country. Under Tenn. Comp. R. and Regs. 0880-06-.02(9), the supervising physician is required to visit any remote site at least once every 30 days.
What Counts as a Remote Site
A remote site is any practice location where the APRN practices that is separate from the physician’s primary practice location. If an APRN operates a standalone clinic, that clinic is a remote site requiring a monthly visit.
The Remote Chart Review Exception
Tennessee provides a limited exception to the on-site review requirement for free clinic or voluntary healthcare settings. Under TCA § 63-7-123(b)(5), an APRN providing services in a free clinic or engaging in voluntary healthcare may arrange for the required personal review of charts by the collaborating physician at the physician’s office or practice site rather than at the clinic site, or remotely via HIPAA-compliant electronic means. This exception applies only to free clinic and voluntary care contexts. It does not extend to standard outpatient, medspa, weight loss, or commercial clinic settings.
Documentation
Each monthly visit must be documented. A supervising physician who visits the remote site monthly but maintains no documentation of those visits has no evidence to produce if the TBOME requests records of compliance.
The 20% Monthly Chart Review Requirement
Tennessee’s chart review obligation is among the most specific in the country. Under Tenn. Comp. R. and Regs. 0880-06-.02(8), the supervising physician must personally review at least 20% of charts monitored or written by the APRN every 30 days.
What This Means in Practice
If an APRN sees 100 patients in a 30-day period, the collaborating physician must personally review at least 20 of those patient charts during that same period. The review must be conducted by the supervising physician personally. It cannot be delegated to another physician who is not designated as the supervising or substitute physician.
The 20% requirement applies across all charts, not only those involving controlled substances or complex cases. It is a minimum floor, not a ceiling.
Documentation of Chart Reviews
Each chart review must be documented. The TBOME expects physicians to maintain records of the reviews conducted, the dates of those reviews, and the charts covered. A physician who conducts reviews but does not document them cannot demonstrate compliance if a board inquiry arises.
Prescription Pad and Documentation Requirements
Tennessee has a specific and unusual requirement regarding prescription pads that distinguishes it from most other states. Under TCA § 63-7-123(3)(A) and Tenn. Comp. R. and Regs. 0880-06-.02(11), every prescription written and signed by an APRN must be issued on a preprinted prescription pad bearing both the name, address, and telephone number of the collaborating physician and the name of the APRN. The APRN must sign each prescription written under the arrangement.
Multi-Physician Pads
Where the preprinted prescription pad contains the names of more than one physician, the APRN must indicate on each prescription which of those physicians is the primary collaborating physician by placing a checkmark beside or a circle around that physician’s name.
This requirement means that changes to the supervising physician arrangement require new prescription pads to be ordered and put into use before prescribing continues under the new physician’s name.
Prescriptive Authority and Controlled Substances in Tennessee
Tennessee APRNs with a certificate of fitness may be authorized to prescribe Schedule II through V controlled substances when that authority is expressly delegated in the CPA.
Controlled Substance Registration
APRNs and PAs authorized to prescribe controlled substances must obtain a Controlled Substance Registration (CSR) from the Tennessee Board of Pharmacy and register with the DEA. Both registrations must be current and active for controlled substance prescribing to be lawful.
The APRN must use DEA numbers assigned to them personally when prescribing controlled substances. Under Tenn. Comp. R. and Regs. 0880-06-.02(12), eligible APRNs shall use their own DEA numbers when prescribing controlled substances.
What the CPA Must Address
The CPA must detail which drug categories and which schedules of controlled substances the APRN is authorized to prescribe. A CPA that authorizes prescribing generally without specifying controlled substance schedules and parameters creates ambiguity that becomes a compliance problem if the prescribing is ever reviewed.
Protocol Update Requirements
Under Tenn. Comp. R. and Regs. 0880-06-.02, the written protocols that govern the APRN’s practice must be signed and updated every two years. This is a separate requirement from the CPA itself. Protocols are the operational guidelines that define how the APRN practices within the agreement’s scope, and they must be kept current.
Protocols that are more than two years old from their last signed update are not compliant regardless of how accurate they may still be in describing the APRN’s practice. Both parties must sign and date the updated protocols at each two-year cycle.
Common Compliance Mistakes Tennessee Collaborating Physicians Make
Tennessee’s compliance obligations are frequent enough that documentation failures are common among physicians who understand their general obligations but underestimate the specificity of each requirement.
- Monthly site visit not conducted or not documented. The visit to every remote practice site must happen every 30 days and must be documented. A physician who visits the clinic but maintains no record of the visit cannot demonstrate compliance.
- 20% chart review not completed each month. Reviewing charts quarterly or on a less frequent schedule does not meet Tennessee’s 30-day cycle. The 20% threshold applies across all charts in each period, not just complex or controlled substance cases.
- Prescription pads not updated after physician change. When the collaborating physician changes, new prescription pads bearing the new physician’s name must be ordered and put into use. Prescriptions written under the old physician’s name after the arrangement has ended are noncompliant.
- Protocols not updated on the two-year cycle. The written protocols must be signed and updated every two years. Protocols that have passed the two-year mark without a documented update are out of compliance regardless of content.
- Substitute physician not designated. The CPA must address substitute physician arrangements. When the primary physician is unavailable, a substitute must be available for consultation. An arrangement with no substitute physician provision leaves the APRN without a compliant oversight structure during the primary physician’s absence.
- Expertise standard not genuinely met. The physician must have experience and expertise in the same area of medicine as the APRN. A physician who signs a CPA for an APRN practicing in a clinical area with no meaningful overlap with the physician’s background is not meeting the expertise standard and creates exposure for both parties.
- Remote chart review used outside the allowed exception. The remote chart review provision applies only to free clinics and voluntary care settings. Physicians who conduct all chart reviews remotely for standard commercial clinic APRNs, citing this provision, are not meeting the standard. Monthly in-person site visits and on-site chart review remain the expectation for commercial practices.
Tennessee Collaborating Physician Requirements: Quick Reference
Physician Eligibility
- Active, unencumbered Tennessee MD or DO license
- Must have experience and expertise in the same area of medicine as the APRN
- Substitute physician must meet the same eligibility requirements
Core Compliance Document
- Written collaborative practice agreement kept at the APRN’s practice site
- Signed and dated by both physician and APRN
- Not filed with either board before practice begins; available for inspection on request
- Must include: party identification, practice protocols, physician availability, chart review process, site visit schedule, prescriptive authority parameters, malpractice coverage
Protocol Update Cycle
- Written protocols signed and updated every two years by both parties
Monthly Site Visit
- Supervising physician must visit every remote practice site at least once every 30 days
- Visit must be documented
- Exception for free clinics and voluntary care settings only
Chart Review
- Supervising physician must personally review at least 20% of the APRN’s charts every 30 days
- Review must be documented
Prescription Pad Requirement
- Preprinted pad bearing the names of both the collaborating physician and the APRN
- APRN must indicate primary physician when pad lists multiple physicians
Prescriptive Authority
- Schedule II through V authorized when expressly delegated in the CPA
- APRN must have CSR from Tennessee Board of Pharmacy and DEA registration
- APRN must use their own DEA number on controlled substance prescriptions
Geographic Requirement
- None for distance; no proximity rule
- Monthly site visit required for all remote practice locations
Physician-to-APRN Ratio
- No fixed statutory cap; determined by the physician’s capacity to fulfill all oversight obligations
Clinics Also Need to Understand Tennessee Collaboration Requirements
While this guide primarily covers the responsibilities and compliance requirements placed on collaborating physicians in Tennessee, these regulations directly affect APRN-owned clinics, medspas, and healthcare practices that depend on physician collaboration to operate. In many cases, clinic owners researching Tennessee collaboration rules are also trying to understand how to find a qualified physician who is willing to conduct monthly site visits, perform the 20% monthly chart review, and maintain the documented oversight trail that Tennessee specifically requires.
Need Help Finding a Tennessee Collaborating Physician?
For clinics, understanding the legal requirements is only one part of the process. The next challenge is finding a qualified physician who has genuine expertise in the same area of medicine as the APRN, is willing to visit the practice site every 30 days, and can consistently meet the 20% monthly chart review obligation across all active arrangements. Whether you are launching a new clinic, replacing a physician whose oversight documentation has lapsed, or managing a growing practice where the existing physician can no longer fulfill the monthly oversight requirements alone, having the right physician relationship in place is essential.
If your clinic is actively looking for a Tennessee collaborating physician, our team can match you with a qualified physician, often within 24 to 48 hours. We work with clinics across Tennessee to simplify the physician matching process while supporting CPA drafting, protocol documentation, and long-term collaboration needs.
Final Thoughts
Tennessee collaborating physician requirements are among the most operationally demanding in the country. The monthly site visit, the 20% monthly chart review, the biennial protocol update cycle, the prescription pad requirement, and the permanent nature of the collaboration obligation create a compliance environment that requires consistent, documented attention every 30 days for as long as the arrangement is active.
For physicians entering the Tennessee market, the most important steps are confirming genuine expertise alignment, establishing a documented monthly site visit and chart review process from the start, ensuring protocols are on a tracked biennial update cycle, and designating a substitute physician so the APRN is never without compliant oversight during the primary physician’s absence.
Build a Compliant Tennessee Collaboration With Collaborating Physician
Are you looking for a collaborating physician role in Tennessee? If you are a licensed Tennessee physician interested in a structured, compliant collaboration arrangement with an APRN-operated clinic, Collaborating Physician handles the infrastructure so you do not have to navigate it alone. The platform connects licensed physicians with vetted clinics across Tennessee and 50-plus other states. Every arrangement is built to meet state-specific requirements, including Tennessee’s CPA standards under TCA § 63-7-123, monthly site visit obligations, 20% monthly chart review requirements, biennial protocol update cycles, and prescription pad documentation standards under Tenn. Comp. R. and Regs. 0880-06-.02. 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 Tennessee clinics with qualified, vetted collaborating physicians who have genuine expertise in the APRN’s practice area and are prepared to fulfill the monthly oversight requirements the state demands. Whether you are launching a new APRN-operated clinic, managing a practice where oversight documentation has fallen behind, or replacing a physician who can no longer meet the 30-day site visit obligation, 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. Tennessee healthcare regulations change frequently. Always verify current requirements directly with the Tennessee Board of Medical Examiners, the Tennessee Board of Nursing, and a qualified healthcare attorney before making any practice decisions.
Frequently Asked Questions
Does a Tennessee collaborating physician need to be physically present at the APRN’s clinic?
The physician does not need to be continuously present at the APRN’s practice location. However, under Tenn. Comp. R. and Regs. 0880-06-.02(9), the supervising physician must visit every remote practice site at least once every 30 days. Remote collaboration is permitted for day-to-day availability, but the monthly in-person visit to each remote location is a separate mandatory requirement that cannot be substituted with remote access except in free clinic and voluntary care settings.
How often must a Tennessee physician review the APRN’s charts?
Under Tenn. Comp. R. and Regs. 0880-06-.02(8), the supervising physician must personally review at least 20% of charts monitored or written by the APRN every 30 days. This is a minimum floor. The review must be conducted by the supervising physician personally and must be documented.
Does a Tennessee CPA need to be filed with the Board of Nursing or the Board of Medical Examiners?
No. The CPA must be kept at the APRN’s practice site and must be available for inspection by either board upon request. It is not submitted to either board as a prerequisite to practice. Both the TBON and the TBOME may request the document at any time.
How often do Tennessee protocols need to be updated?
Under Tenn. Comp. R. and Regs. 0880-06-.02, the written protocols that govern the APRN’s practice must be signed and updated every two years. Both the physician and the APRN must sign the updated protocols at each renewal. A protocol that has passed the two-year mark without a signed update is out of compliance.
Can a Tennessee APRN prescribe Schedule II controlled substances?
Yes, when that authority is expressly delegated in the CPA. The CPA must detail which drug categories and schedules the APRN is authorized to prescribe. The APRN must hold a Controlled Substance Registration from the Tennessee Board of Pharmacy and a DEA registration to prescribe controlled substances, and must use their own DEA number on all controlled substance prescriptions.
How many APRNs can one Tennessee physician supervise?
Tennessee does not set a fixed statutory cap. The number a physician may supervise should be determined by the physician at the practice level, consistent with good medical practice. As a practical matter, the physician must be able to conduct monthly site visits and 20% monthly chart reviews for every active APRN under their supervision. The oversight obligations are the real limiting factor, not a numerical rule.
