Maryland collaborating physician requirements reflect a full-practice-authority state that has been operating under that framework for over a decade. Maryland’s Nurse Practitioner Full Practice Authority Act, passed in 2015, eliminated the mandatory physician attestation requirement that had previously required certified registered nurse practitioners to identify a physician collaborator. Experienced Maryland CRNPs may now practice, diagnose, and prescribe, including controlled substances in Schedules II through V, without any physician collaboration agreement, protocol, or oversight requirement under state law.
For physicians in Maryland, the relevant compliance framework centers on two remaining contexts: the 18-month mentorship requirement for new NPs who have never been certified in any state, and the physician supervision structure that applies to physician assistants. This guide covers both frameworks in full, clarifies what full practice authority means for the physician’s role, and explains what collaboration obligations remain active in 2026.
Maryland Collaborating Physician Overview: Where Maryland Stands
Maryland is a full-practice-authority state for certified registered nurse practitioners under the American Association of Nurse Practitioners’ classification. The Maryland Board of Nursing regulates CRNP practice under Health Occupations Article Title 8 and COMAR 10.27.07 as the sole licensing authority. Physician involvement in CRNP practice is not required by state law for experienced NPs and is limited to the mentorship structure for new NPs under COMAR 10.27.07.02(A)(4).
Governing Bodies
Two regulatory bodies govern healthcare providers in Maryland:
- Maryland Board of Nursing (MBON): Governs CRNP certification, the mentor requirement for new NPs, prescriptive authority, controlled substance registration, and disciplinary matters under Health Occupations Article Title 8 and COMAR 10.27.07.
- Maryland Board of Physicians (MBP): Governs physician licensure, PA supervision agreements, and disciplinary matters under Health Occupations Article Title 14 and applicable COMAR regulations.
The 2015 Transition
The Maryland legislature passed SB 723/HB 999 in 2015, eliminating the mandatory physician attestation requirement that had required CRNPs to identify one physician collaborator since 2010. The new framework removed the formal legal requirement for physician involvement in experienced NP practice entirely and replaced the physician attestation with a more limited mentorship requirement applicable only to new NPs entering the profession for the first time. Maryland has operated under this full practice authority framework ever since.
Full Practice Authority in Maryland: What It Means for Physicians
Under Maryland full practice authority, experienced CRNPs may do all of the following without any physician involvement:
- Independently perform comprehensive health assessments
- Diagnose and treat acute and chronic conditions
- Develop and manage patient care plans
- Prescribe legend drugs, therapeutic devices, and controlled substances
- Order, interpret, and act on laboratory and diagnostic tests
- Refer patients to appropriate licensed physicians or other healthcare providers as clinically needed
- Open and operate independent practices
The MBON now identifies Maryland as a full practice state. The AANP confirms full practice authority for Maryland CRNPs under the Board of Nursing’s exclusive regulatory authority.
What Collaboration Means in Maryland
The term collaboration in Maryland law describes a cooperative professional relationship between healthcare providers, not a formal regulatory requirement. Under COMAR 10.27.07, collaboration means a cooperative relationship with other health care providers. This is a professional practice standard reflecting how good clinical care works, not a legally mandated oversight structure that requires a formal agreement, board filing, or documented oversight process.
CRNPs in Maryland are expected to consult with physicians, refer complex patients, and work cooperatively as part of a healthcare team as appropriate for the clinical situation. None of this requires a formal collaboration agreement or a designated supervising physician.
The 18-Month Mentorship: What New NPs Require
Maryland’s full practice authority framework includes one specific physician involvement provision that applies only to a narrow category of NPs. Under COMAR 10.27.07.02(A)(4), an NP who applies for initial CRNP certification and has never been certified as a nurse practitioner in Maryland or any other state must identify a mentor.
Who Is a Mentor
Under COMAR 10.27.07.01(B)(7), a mentor is defined as a certified nurse practitioner or physician, licensed in Maryland, who:
- Has three or more years of clinical practice experience
- Will be available for advice, consultation, and collaboration as needed for 18 months beginning on the date an application is received by the MBON from an applicant who has never been certified in this or any other state
The Critical Distinction: Physician or Experienced CRNP
A mentor in Maryland does not have to be a physician. An experienced Maryland-certified CRNP with three or more years of clinical practice experience satisfies the mentor requirement equally. The physician role in this mentorship is optional, not mandatory.
What the Mentorship Requires
The mentor’s obligation under COMAR 10.27.07.02 is to be available for advice, consultation, and collaboration as needed throughout the 18-month period. There is no requirement for:
- A formal written agreement filed with the MBON
- Chart reviews or documented oversight activities
- A specific number of meetings or consultations
- Geographic proximity between mentor and new NP
- Pre-approval of the mentorship by any state board
- The mentor to co-sign prescriptions or authorize the NP’s prescribing
The mentorship is an availability and consultation relationship, not a supervision model. The new NP practices independently and calls upon the mentor when questions arise.
Duration
The 18-month mentorship period begins on the date the initial CRNP certification application is received by the MBON. Once 18 months have passed, the mentorship obligation ends. No application or board notification is required to conclude the mentorship period.
What a Maryland Mentor Must Be and Do
A physician serving as a Maryland CRNP mentor should understand the limited scope of that role clearly.
The Mentor Is Not a Supervising Physician
The Maryland mentorship model is fundamentally different from the collaborative physician frameworks in restricted-practice states. The physician mentor:
- Does not bear regulatory responsibility for the NP’s clinical decisions
- Does not need to review or approve prescriptions
- Is not required to co-develop protocols or standardized procedures
- Does not need to be identified in any board filing as a supervisor
- Does not need to maintain chart review records
- Does not face disciplinary action if the NP prescribes outside their scope, so long as the physician was genuinely available as a consultant
The Mentor’s Actual Obligation
The mentor’s only obligation is to be available for advice, consultation, and collaboration as needed during the 18-month period. In practice, this means being reachable by phone or electronic communication when the new NP has a clinical question and being willing to consult on patient care matters the NP brings forward.
Informal but Real
Although the mentorship structure is far less formal than a traditional collaboration agreement, it represents a genuine professional commitment. A physician who agrees to mentor a new NP should be prepared to actually respond to consultation requests during that period.
Physician Eligibility for the Mentor Role
A physician serving as a Maryland CRNP mentor must hold a current, active Maryland medical license and must have three or more years of clinical practice experience. There is no specialty alignment requirement for the mentorship role under Maryland law. The mentor’s clinical background does not need to match the CRNP’s specialty area under current COMAR rules.
No Board Pre-Approval
Maryland does not require the physician to file any application or receive pre-approval from the MBON or MBP to serve as a CRNP mentor. The mentorship is disclosed by the CRNP as part of their initial certification application, and the physician is named in that application. The physician does not submit a separate registration.
Prescriptive Authority and Controlled Substances in Maryland
Maryland CRNPs may independently prescribe and dispense drugs, devices, and Schedules II through V controlled substances under the exclusive licensure authority of the MBON. Physician involvement is not required for any aspect of CRNP prescribing for experienced NPs.
Maryland Drug Control Number
To prescribe controlled substances, a CRNP must obtain a Maryland Drug Control Number in addition to a federal DEA registration. The Maryland Drug Control Number is issued by the Maryland Board of Nursing and is required for all controlled substance prescribing in the state.
New NPs During the 18-Month Mentorship
During the 18-month mentorship period for new NPs, the CRNP may prescribe independently. The mentor’s availability for consultation during this period supports the new NP’s clinical decision-making but does not create a delegated prescribing structure. The NP prescribes under their own authority, not under the physician’s delegation.
Prescription Monitoring Program
Maryland CRNPs prescribing controlled substances must comply with the Maryland Prescription Drug Monitoring Program (PDMP) requirements, including checking the PDMP before prescribing opioids and other controlled substances under applicable state requirements.
Where Active Physician Collaboration Still Applies in Maryland
Despite full practice authority for CRNPs, physician collaboration and supervision remain active in two important contexts in Maryland.
Physician Assistant Supervision
Physician assistants in Maryland are not covered by the CRNP full practice authority framework. PAs must practice under a supervision agreement with a licensed Maryland physician. The Maryland Board of Physicians governs PA supervision arrangements under Health Occupations Article Title 15.
Voluntary Collaboration Arrangements
Nothing in Maryland law prevents CRNPs from voluntarily entering into clinical collaboration arrangements with physicians for professional, institutional, or credentialing reasons. Some health systems, hospitals, and managed care organizations require physician collaboration for all advanced practice providers regardless of state law. These are contractual and institutional arrangements, not regulatory requirements.
The PA Collaboration Framework in Maryland
For physicians seeking collaboration income in Maryland from PA-based arrangements, the active statutory framework applies under Health Occupations Article Title 15 and COMAR 10.32.05 through 10.32.07.
What PA Supervision in Maryland Requires
Maryland PAs must practice under the supervision of a licensed Maryland physician. The supervising physician must hold a current, active, and unrestricted Maryland medical license. The physician and PA must have a written supervision agreement that describes the PA’s authorized scope of practice.
Key PA Supervision Obligations
Under Maryland PA supervision requirements, the supervising physician must:
- Be available for consultation with the PA, either in person or by telecommunication, at all times when the PA is seeing patients
- Participate in the review of the PA’s patient records to ensure quality of care
- Retain supervisory responsibility for the care provided by the PA
Geographic Proximity
Maryland does not impose a specific mileage requirement for physician-PA supervision. Remote supervision by telecommunication is permitted as long as the physician is genuinely available during the PA’s practice hours.
The Supervision Agreement
The supervision agreement between the physician and PA must describe the scope of practice authorized, how supervision will occur, and how the PA will access the physician for consultations and emergencies. The agreement should be maintained at the practice site and updated when scope or practice circumstances change.
Common Compliance Considerations for Maryland Collaborating Physicians
Because Maryland is a full practice authority state, most compliance considerations for physicians center on the mentorship role and PA supervision rather than the CRNP collaborative framework common in restricted-practice states.
- Misunderstanding the mentorship as a supervision role. A physician who serves as a mentor for a new Maryland CRNP is not the NP’s supervising physician. The physician does not bear regulatory responsibility for the NP’s clinical decisions. Treating the mentorship as equivalent to a collaborative practice agreement in a restricted state creates unnecessary liability exposure.
- Not being genuinely available during the 18-month period. Although the mentorship is informal, the physician must be available for advice, consultation, and collaboration as needed. A physician who agrees to mentor a new NP but is consistently unresponsive is not fulfilling the commitment described in COMAR 10.27.07.02.
- Failing to distinguish CRNP and PA oversight frameworks. Maryland’s full practice authority applies to CRNPs and CNMs. PAs in Maryland still require physician supervision under a separate statutory framework. Physicians working with both CRNPs and PAs must apply the correct oversight structure to each provider type.
- Voluntary collaboration agreements without legal review. Some Maryland CRNPs voluntarily enter into collaboration arrangements with physicians for insurance credentialing or institutional purposes. These are contractual arrangements, not statutory requirements. Physicians entering voluntary arrangements should ensure the agreement language does not inadvertently create supervision obligations or liability exposure beyond what both parties intend.
Maryland Collaborating Physician Requirements: Quick Reference
NP Practice Authority
- Maryland is a full practice authority state for CRNPs
- No physician collaboration agreement, attestation, or supervision required for experienced NPs
- Collaboration means a cooperative clinical relationship, not a formal regulatory requirement
Mentorship (New NPs Only)
- Applies only to NPs who have never been certified in Maryland or any other state
- Mentor must be a physician OR experienced CRNP with 3+ years of clinical practice, licensed in Maryland
- Mentor must be available for advice, consultation, and collaboration as needed for 18 months from initial application date
- No formal written agreement filed with state; no chart review requirement; no geographic proximity requirement
- New NP prescribes independently throughout the mentorship period
Physician Eligibility for Mentorship
- Active, current Maryland MD or DO license
- Three or more years of clinical practice experience
- No specialty alignment requirement; no pre-approval or board registration required
Prescriptive Authority
- CRNPs may independently prescribe Schedule II through V controlled substances
- Maryland Drug Control Number and DEA registration required
- No physician delegation required for CRNP prescribing
PA Supervision (Active Requirement)
- PAs require a written supervision agreement with a licensed Maryland physician
- Physician must be available for consultation at all times during PA practice
- Physician participates in review of PA patient records
Geographic Requirement
- None for CRNP mentorship or PA supervision
Physician-to-NP Ratio
- No statutory cap
Clinics Also Need to Understand Maryland Collaboration Requirements
While this guide primarily covers what physician collaboration means in Maryland, these frameworks directly affect CRNP-operated and PA-operated clinics across the state. In many cases, clinic owners researching Maryland collaboration rules are trying to understand whether their specific provider type requires any physician involvement and, if so, what form that involvement must take.
Need Help Finding a Maryland Collaborating Physician?
For clinics with PAs, the next challenge is finding a qualified supervising physician who is genuinely available for consultation, understands Maryland’s PA supervision requirements, and is prepared to participate in PA patient record reviews. For clinics launching with new CRNPs who require a mentor for their first 18 months, finding a qualified physician or experienced CRNP willing to serve in that consultative role is the first step.
If your clinic is actively looking for a Maryland collaborating physician, our team can match you with a qualified physician, often within 24 to 48 hours. We work with clinics across Maryland to simplify the physician matching process while supporting PA supervision agreement drafting, mentorship arrangements, and long-term collaboration needs.
Final Thoughts
Maryland collaborating physician requirements reflect a state that resolved the physician-NP collaboration debate in 2015 by removing the mandatory collaboration requirement entirely for experienced NPs. The framework that replaced it, centered on an 18-month mentorship for first-time NPs, creates a limited and genuinely supportive role for physicians in the early stage of new NP practice, not a career-long oversight structure.
For physicians in Maryland, the active collaboration opportunities are concentrated in PA supervision arrangements, where the statutory supervision framework remains in place, and in voluntary clinical partnerships with NPs that exist for professional, institutional, or credentialing reasons rather than regulatory compliance.
Build a Compliant Maryland Collaboration With Collaborating Physician
Are you looking for a collaborating physician role in Maryland? If you are a licensed Maryland physician interested in a structured, compliant collaboration arrangement, whether as a PA supervising physician or as an 18-month mentor for a new CRNP, Collaborating Physician handles the infrastructure so you do not have to navigate it alone. The platform connects licensed physicians with vetted clinics across Maryland and 50-plus other states. Every arrangement is built to meet state-specific requirements, including Maryland’s PA supervision standards under Health Occupations Article Title 15, the CRNP mentorship framework under COMAR 10.27.07, and the consultation availability obligations that apply throughout each arrangement. 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 Maryland clinics with qualified, vetted physicians who understand the full practice authority framework for CRNPs, the 18-month mentorship structure for new NPs, and the active supervision requirements for PAs. Whether you are launching a new CRNP-operated clinic, onboarding a new NP who needs an 18-month mentor, or staffing a PA-based practice that requires a supervising physician, 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. Maryland healthcare regulations may change. Always verify current requirements directly with the Maryland Board of Nursing, the Maryland Board of Physicians, and a qualified healthcare attorney before making any practice decisions.
Frequently Asked Questions
Does a Maryland NP need a collaborating physician?
For experienced NPs, no. Maryland is a full-practice-authority state. CRNPs who have already been certified in Maryland or any other state may practice, diagnose, and prescribe, including controlled substances, without any physician collaboration agreement, attestation, or supervision under Maryland law. The only physician involvement requirement applies to NPs applying for initial certification who have never been certified in any state, who must identify a mentor for their first 18 months.
What is the 18-month mentorship requirement in Maryland?
Under COMAR 10.27.07.02(A)(4), an NP applying for initial CRNP certification who has never been certified in Maryland or any other state must identify a mentor. The mentor must be a physician or experienced CRNP licensed in Maryland with three or more years of clinical practice experience, who will be available for advice, consultation, and collaboration as needed for 18 months from the date the application is received by the MBON. There is no requirement that the mentor be a physician specifically.
Does the Maryland mentor need to review the new NP’s charts or co-sign prescriptions?
No. The mentor’s obligation is to be available for advice, consultation, and collaboration as needed. There is no chart review requirement, no prescription co-signature requirement, no formal written agreement required to be filed with the state, and no documentation standard tied to the mentorship beyond the NP’s identification of the mentor in their initial certification application.
Can a Maryland NP prescribe Schedule II controlled substances independently?
Yes. Maryland CRNPs may independently prescribe and dispense Schedule II through V controlled substances under the exclusive licensure authority of the MBON. A Maryland Drug Control Number and a federal DEA registration are required. No physician delegation or agreement is needed for any aspect of CRNP controlled substance prescribing for experienced NPs.
Do Maryland PAs need a collaborating physician?
Yes. Maryland PAs must practice under a written supervision agreement with a licensed Maryland physician. The PA supervision framework under Health Occupations Article Title 15 applies separately from the CRNP full practice authority framework and was not changed by the 2015 NP legislation. Physicians supervising Maryland PAs must be available for consultation during practice hours and must participate in PA patient record reviews.
Is any written agreement required for Maryland CRNP mentorship?
No formal written agreement needs to be filed with the MBON for the mentorship arrangement. The CRNP identifies the mentor in their initial certification application, naming the mentor by name and license status. No separate registration, board approval, or formal written contract between the physician and the new NP is required by state rule. The mentorship is a professional availability commitment, not a regulatory filing.
