Kentucky collaborating physician requirements apply to a reduced-practice state with one of the most structurally distinct collaboration frameworks in the country. Kentucky does not use a single collaborative practice agreement for all prescribing. Instead, the state requires two separate written agreements depending on what the APRN will prescribe: the Collaborative Agreement for the Advanced Practice Registered Nurse’s Prescriptive Authority for Nonscheduled Legend Drugs, known as a CAPA-NS, and the Collaborative Agreement for the Advanced Practice Registered Nurse’s Prescriptive Authority for Controlled Substances, known as a CAPA-CS. Each has different eligibility requirements, different physician obligations, and different pathways toward independence.
For physicians entering collaboration roles in Kentucky, understanding which agreement applies to the specific APRN and what each agreement requires is the foundation of a compliant arrangement. This guide covers every requirement a physician needs to understand in 2026, sourced directly from KRS § 314.042 and Kentucky Administrative Regulations 201 KAR 20:057.
Kentucky Collaborating Physician Overview: Where Kentucky Stands
Kentucky classifies APRNs in the reduced-practice category. APRNs may practice and diagnose without a physician agreement, but both nonscheduled legend drug prescribing and controlled substance prescribing require written physician collaboration agreements until the APRN meets defined independence thresholds. The duration of the collaboration requirement depends on which prescribing authority is involved.
Governing Bodies
Two regulatory bodies govern APRN-physician collaboration in Kentucky:
- Kentucky Board of Nursing (KBN): Governs APRN licensure, CAPA-NS and CAPA-CS notification filings, prescriptive authority standards, unannounced practice site inspections, and disciplinary oversight under KRS § 314.042 and 201 KAR 20:057.
- Kentucky Board of Medical Licensure (KBML): Governs physician licensure and audits of CAPA-CS collaboration meetings. Both the KBN and the KBML may conduct audits of CAPA-CS meeting documentation. The audit’s sole purpose is to document that the required quarterly meetings have taken place and that other CAPA-CS provisions have been met.
Unannounced Inspections
Under 201 KAR 20:057, Section 9, the Kentucky Board of Nursing may make an unannounced visit to an APRN’s practice to determine if it is consistent with KRS Chapter 314 requirements. Patient and prescribing records must be made available for immediate inspection. Physicians in active Kentucky collaboration arrangements should ensure their APRNs maintain current, complete records that can withstand an unannounced board review.
The Two-Agreement Framework: CAPA-NS and CAPA-CS
Kentucky’s dual-agreement structure is the defining feature of this state’s collaboration framework. Most other states in this series use a single collaboration document for all prescribing. Kentucky separates the authority into two distinct written instruments based on drug schedule.
CAPA-NS: Nonscheduled Legend Drugs
The CAPA-NS governs the APRN’s authority to prescribe nonscheduled (non-controlled) prescription medications. This agreement is required for the first four years of the APRN’s prescribing career as a certified nurse practitioner, clinical nurse specialist, or certified nurse midwife. After four years of prescribing with a CAPA-NS in good standing, the APRN may notify the KBN and discontinue the CAPA-NS, prescribing nonscheduled legend drugs independently.
CAPA-CS: Controlled Substances
The CAPA-CS governs the APRN’s authority to prescribe controlled substances. This is a separate agreement with additional requirements including a same or similar specialty physician, a quarterly KASPER review meeting obligation, employment within a healthcare entity, and a DEA and KASPER registration requirement. The CAPA-CS pathway to independence is different from the CAPA-NS pathway and is addressed separately in this guide.
The CAPA-NS: Nonscheduled Legend Drug Prescribing
Under KRS § 314.042(12), before an APRN may prescribe nonscheduled legend drugs, the APRN must enter into a written CAPA-NS with a physician who holds an active, unrestricted Kentucky license in a same or similar specialty.
CAPA-NS Notification to the KBN
The APRN must notify the KBN of the existence of a CAPA-NS by filing the APRN Prescriptive Authority Notification Form through the KBN portal at kbn.ky.gov. The physician does not file a separate registration but should confirm that the APRN has completed this notification before nonscheduled prescribing begins.
Four-Year Duration
The CAPA-NS requirement applies for the first four years of the APRN’s prescribing career. After four years of prescribing with a CAPA-NS:
- The APRN must notify the KBN using the APRN Prescriptive Authority Notification Form that the four-year requirement has been met and that the APRN will be prescribing nonscheduled legend drugs without a CAPA-NS
- The APRN may no longer be required to maintain a CAPA-NS and cannot be compelled to maintain one as a condition of prescribing
- If the APRN’s license is not in good standing, the CAPA-NS requirement is not removed until the license is restored to good standing
An APRN may choose to maintain a CAPA-NS indefinitely after the four-year period expires, but it is no longer a legal requirement.
Endorsement Exception for CAPA-NS
An APRN wishing to practice in Kentucky through licensure by endorsement is exempt from the CAPA-NS requirement if the APRN has met the prescribing requirements in a state that grants independent prescribing authority to APRNs.
The CAPA-CS: Controlled Substance Prescribing
Under KRS § 314.042(11), before an APRN may prescribe controlled substances, the APRN must enter into a written CAPA-CS with a physician who holds an active, unrestricted Kentucky license in a same or similar specialty.
Who Can Enter a CAPA-CS
Before engaging in the prescribing of controlled substances, the APRN must either:
- Have been licensed to practice as an APRN for one year with the Kentucky Board of Nursing, or
- Have been granted a CAPA-CS exemption by the board under KRS 314.042(14)(e) prior to the date the medications were prescribed
CAPA-CS KBN Notification and Documentation
The APRN must, through the KBN portal:
- Notify the KBN that the APRN has entered into a CAPA-CS agreement
- Upload a copy of the Kentucky DEA registration
- Upload verification of having a PDMP/KASPER master account
All of these steps must be completed before controlled substance prescribing begins. The physician should confirm that all three filings have been made through the KBN portal before the APRN writes any controlled substance prescription.
The Standardized CAPA-CS Form
Kentucky requires use of the standardized CAPA-CS form developed by the state. Under KRS § 314.042, the standardized CAPA-CS form shall be used by all APRNs and all physicians in Kentucky who enter into a CAPA-CS. The parties may not substitute a custom form.
What Must Be in a Kentucky Collaboration Agreement
Both the CAPA-NS and the CAPA-CS must address the core elements of the prescribing collaboration. Under 201 KAR 20:057, the agreements must establish:
1. Party Identification and Specialty
Both agreements must identify the APRN and the collaborating physician by name and license information. The physician’s specialty must be the same or similar to the APRN’s area of practice, and the board will consider the facts of each situation and the scope of both parties’ actual practice when evaluating specialty comparability.
2. Scope of Prescribing
The agreements must describe the scope of prescribing authority delegated, including the drug categories and, for the CAPA-CS, the specific schedules of controlled substances authorized.
3. Practice Address
An APRN with a CAPA-NS or CAPA-CS must report a practice address to the board. A change to the practice address must be reported to the board within 30 days.
4. For CAPA-CS: Quarterly KASPER Review Meetings
The CAPA-CS must reflect the quarterly meeting obligation described in the next section.
Board Notification Requirements
Kentucky’s notification framework is distinctive for two reasons: it is the APRN’s obligation to file, not the physician’s, and all notifications must be submitted through the KBN portal.
CAPA-NS Notification
The APRN files the APRN Prescriptive Authority Notification Form through kbn.ky.gov to notify the KBN of the CAPA-NS. This notification must be filed before nonscheduled prescribing begins.
CAPA-CS Notification and Documentation
The APRN notifies the KBN of the CAPA-CS through the same portal and uploads both the DEA registration copy and KASPER master account verification. All three items must be in the KBN portal before controlled substance prescribing begins.
Rescission Notifications
When an APRN discontinues a CAPA-NS or CAPA-CS, a Rescission Form must be provided to the KBN. The physician should confirm that the APRN has filed the Rescission Form promptly when any arrangement ends.
30-Day Address Change Reporting
Any change to the APRN’s practice address must be reported to the KBN within 30 days. Physicians should ensure the APRNs they collaborate with are maintaining current address records in the board portal.
Physician Eligibility: The Same or Similar Specialty Standard
A qualifying Kentucky collaborating physician must hold an active, unrestricted Kentucky medical license. Kentucky imposes a same or similar specialty requirement for both the CAPA-NS and CAPA-CS.
How Specialty Comparability Is Evaluated
Under 201 KAR 20:057(3), in determining whether the APRN and the collaborating physician are qualified in the same or a similar specialty, the board shall consider the facts of each particular situation and the scope of the APRN’s and the physician’s actual practice. This is a facts-and-circumstances analysis, not a binary specialty match requirement. A family medicine physician collaborating with a family NP clearly satisfies the standard. A primary care physician collaborating with a psychiatric NP requires more careful analysis of each party’s actual clinical practice.
No Geographic Proximity Requirement
Kentucky does not impose a geographic proximity requirement on collaborating physicians. Remote collaboration is fully permitted. A physician in Lexington may serve as a collaborating physician for an APRN in Pikeville without any proximity restriction.
No Ratio Limit
Kentucky does not impose a statutory cap on the number of APRNs a physician may enter into CAPA-NS or CAPA-CS agreements with simultaneously. The physician must be able to genuinely fulfill the collaboration obligations, including the quarterly KASPER meeting for each active CAPA-CS.
The Quarterly KASPER Review Meeting
The quarterly KASPER review meeting is one of Kentucky’s most operationally specific and important ongoing obligations for physicians in CAPA-CS arrangements. It has no equivalent in most other states in this series.
What KASPER Is
KASPER is the Kentucky All Schedule Prescription Electronic Reporting System, established under KRS § 218A.202. It is Kentucky’s prescription drug monitoring program. The APRN must register with KASPER and maintain a KASPER master account as a condition of the CAPA-CS.
The Meeting Requirement
Under KRS § 314.042 and confirmed by the KBN, an APRN with a CAPA-CS must meet with the collaborating physician at least quarterly to review the APRN’s reverse KASPER report or the current PDMP in use in Kentucky. The purpose of the review is to assess the APRN’s controlled substance prescribing patterns and discuss any concerns.
What the Reverse KASPER Report Shows
A reverse KASPER report shows prescriptions written by the APRN that appear in the KASPER system. Reviewing this report allows the physician to assess the APRN’s controlled substance prescribing patterns, identify any outliers, and discuss appropriate prescribing practices in the context of the APRN’s patient population.
The review may include information from the patient’s medical record that relates to the conditions being treated with controlled substances, to facilitate meaningful discussion.
Documentation Required
A record of the meeting date, a summary of discussions, and any recommendations made must be written down. Both the physician and the APRN must retain a copy for a period of one year past the expiration of the CAPA-CS. These records are subject to audit by both the KBN for the APRN and by the KBML for the physician. The audit’s purpose is to confirm that the meetings occurred and that the CAPA-CS provisions were met.
What Happens If Meetings Are Missed
Missing quarterly KASPER meetings creates audit exposure for both the physician and the APRN. The KBML can investigate the physician’s collaboration practices based on missing meeting documentation, independent of any APRN complaint or investigation.
The Four-Year Independence Pathways
Kentucky’s CAPA-NS and CAPA-CS frameworks each have a defined four-year pathway toward independence. The pathways are separate and each requires its own process.
CAPA-NS Independence After Four Years
After four years of prescribing nonscheduled legend drugs with a CAPA-NS in collaboration with a physician, an APRN in good standing may notify the KBN and discontinue the CAPA-NS. No further physician collaboration is required for nonscheduled prescribing after this notification.
CAPA-CS Independence After Four Years
Under KRS § 314.042(14), an APRN may apply to the KBN for a CAPA-CS exemption after meeting specific criteria, including:
- The APRN has been prescribing for at least four years
- The APRN’s license is in good standing with the KBN
The exemption process involves a review by the KBN that includes a criminal background check and a check of the coordinated licensure information system for any unreported disciplinary actions in other states. The APRN must cooperate with supplemental documentation requests before the board makes a determination.
Endorsement Exception for CAPA-CS
An APRN wishing to practice in Kentucky through licensure by endorsement may request a CAPA-CS exemption if the APRN has met the prescribing requirements for controlled substances in a state that grants such authority to APRNs, has had authority to prescribe controlled substances for at least four years, and meets the other board requirements.
What the Physician’s Independence Attestation Involves
Neither the CAPA-NS nor the CAPA-CS independence process requires a formal physician attestation. The exemption application is submitted by the APRN, not the physician. However, physicians should maintain complete records of the collaboration throughout the four-year period so they can respond accurately if the KBN requests documentation during the exemption review.
Prescriptive Authority and Controlled Substance Supply Limits
Kentucky imposes specific supply limits on APRN controlled substance prescribing under KRS § 314.042 and 201 KAR 20:057.
Schedule II Controlled Substances
Prescriptions for Schedule II controlled substances from APRNs are limited to a 30-day supply without refill. This limit applies to all Schedule II prescriptions under the CAPA-CS framework.
Schedule III Controlled Substances
Prescriptions for Schedule III controlled substances are limited to a 30-day supply without any refill.
Schedule IV and V Controlled Substances
Prescriptions for Schedules IV and V controlled substances are limited to the original prescription and refills not to exceed a six-month supply total.
DEA and KASPER Requirements
The APRN must hold a Kentucky DEA registration, which must be uploaded to the KBN portal as part of the CAPA-CS notification. Within 30 days of obtaining a DEA registration, the APRN must register with the KASPER electronic monitoring system and provide a copy of the KASPER registration to the board.
The Employment Requirement for CAPA-CS
One of Kentucky’s most distinctive CAPA-CS requirements is the employment condition. Under KRS § 314.042 and KBN guidance, an APRN with a CAPA-CS must be employed by a healthcare entity or provider. The APRN cannot hold a CAPA-CS as an independent contractor without a qualifying employment relationship.
If the Provider Is an APRN
If the healthcare entity employing the APRN is itself an APRN, the employing APRN must have been granted a CAPA-CS exemption by the board. An APRN-owned practice that employs another APRN must therefore hold either a CAPA-CS exemption at the practice owner level or be working with a physician employer who satisfies the employment condition.
This requirement is one of the most consequential for NP-owned clinics in Kentucky that wish to have employees or associates who prescribe controlled substances. Clinic owners who are APRNs must first obtain their own CAPA-CS exemption before they can serve as the employer for another APRN’s CAPA-CS.
Termination and the 30-Day Grace Period
When a CAPA-NS or CAPA-CS ends unexpectedly, Kentucky provides a limited grace period for nonscheduled prescribing but not for controlled substances.
CAPA-NS Unexpected Termination
If a CAPA-NS ends unexpectedly without notice, with the physician’s license becoming invalid in Kentucky, or upon the death of the physician, the APRN may continue to prescribe nonscheduled legend drugs for 30 days. During this period, the APRN must document in each patient’s medical record the professional determination that continued prescribing is justified based on the individual facts of each patient’s diagnosis and treatment. This 30-day grace period cannot be extended or occur successively.
CAPA-CS Unexpected Termination
There is no grace period for controlled substance prescribing when a CAPA-CS ends unexpectedly. An APRN with a CAPA-CS must cease prescribing controlled substances immediately if the collaborative agreement ends, until the CAPA-CS is resumed or the APRN enters into a new CAPA-CS.
This distinction between CAPA-NS and CAPA-CS termination grace periods is critical for clinic continuity planning. A physician who exits a CAPA-CS arrangement will require the APRN to stop all controlled substance prescribing immediately, even if patient care is ongoing.
Common Compliance Mistakes Kentucky Collaborating Physicians Make
- Quarterly KASPER meetings not documented. The meeting date, discussion summary, and any recommendations must be written and retained by both parties for one year past the CAPA-CS expiration. Undocumented meetings create audit exposure for both the physician and the APRN.
- Physician does not meet the same or similar specialty standard. The board evaluates specialty comparability based on actual practice scope, not just licensure. A physician whose daily clinical practice has no meaningful overlap with the APRN’s patient population may not satisfy the standard.
- CAPA-CS entered without confirming the APRN has been licensed for one year. An APRN must generally be licensed as an APRN for one year with the KBN before entering a CAPA-CS. Physicians who execute CAPA-CS agreements with APRNs before this one-year threshold is met are entering arrangements the APRN is not yet eligible for.
- Controlled substance prescribing not stopped immediately when CAPA-CS ends. Unlike the CAPA-NS, there is no 30-day grace period for controlled substances when a CAPA-CS terminates. An APRN must cease controlled substance prescribing immediately when the CAPA-CS ends, even during patient care transitions. Physicians who end arrangements without planning for this impact on patient care create acute compliance risks.
- Custom CAPA-CS form used instead of the standardized form. Kentucky requires the standardized CAPA-CS form for all arrangements. A custom agreement does not satisfy the statutory requirement regardless of how comprehensive it may be.
- Practice address change not reported within 30 days. An APRN’s change in practice address must be reported to the KBN within 30 days. Physicians should confirm with their APRNs that address changes are being reported promptly.
Kentucky Collaborating Physician Requirements: Quick Reference
Physician Eligibility
- Active, unrestricted Kentucky MD or DO license
- Same or similar specialty as the APRN’s population focus and area of practice
- No geographic proximity requirement; no ratio limit
CAPA-NS (Nonscheduled Legend Drug Prescribing)
- Required for the first four years of the APRN’s prescribing career
- Physician must hold active, unrestricted Kentucky license in same or similar specialty
- APRN notifies KBN through portal before nonscheduled prescribing begins
- After four years of prescribing with CAPA-NS, APRN may notify KBN and prescribe independently
- 30-day grace period if CAPA-NS ends unexpectedly
CAPA-CS (Controlled Substance Prescribing)
- Required before an APRN may prescribe controlled substances
- APRN must be licensed as an APRN in Kentucky for one year, or hold a board-granted exemption
- Standardized CAPA-CS form required; no custom forms
- APRN notifies KBN through portal; uploads DEA registration and KASPER master account verification
- APRN must be employed by a healthcare entity or provider
- Quarterly KASPER review meetings required; documented with date, discussion summary, and recommendations; retained one year past CAPA-CS expiration
- Both KBN and KBML may audit CAPA-CS meeting documentation
- No grace period when CAPA-CS ends; controlled substance prescribing must stop immediately
Controlled Substance Supply Limits
- Schedule II: 30-day supply without refill
- Schedule III: 30-day supply without refill
- Schedule IV and V: original prescription plus refills not exceeding six-month total supply
CAPA-CS Independence Pathway
- After four years of CAPA-CS prescribing, APRN may apply to KBN for CAPA-CS exemption
- Board conducts criminal background check and licensure system review
- Endorsement applicants from independent prescribing states may receive expedited exemption
Clinics Also Need to Understand Kentucky Collaboration Requirements
While this guide primarily covers the physician collaboration requirements in Kentucky, these regulations directly affect APRN-owned clinics, medspas, and healthcare practices that depend on physician collaboration to operate. In many cases, clinic owners researching Kentucky collaboration rules are also trying to understand the CAPA-NS and CAPA-CS distinction, the same or similar specialty requirement, the employment condition for CAPA-CS, and whether a physician whose controlled substance prescribing specialty aligns with the clinic’s services is available.
Need Help Finding a Kentucky Collaborating Physician?
For clinics, understanding Kentucky’s two-agreement structure is only one part of the process. The next challenge is finding a qualified physician whose specialty satisfies the same or similar standard, who is prepared to attend and document quarterly KASPER review meetings for any CAPA-CS, and who understands that controlled substance prescribing must stop immediately if the CAPA-CS ends without a grace period. Whether you are launching a new clinic, replacing a physician who has exited a CAPA-CS arrangement and creating an urgent need for controlled substance coverage, or managing the four-year pathway toward APRN prescribing independence, having the right physician in place is essential.
If your clinic is actively looking for a Kentucky collaborating physician, our team can match you with a qualified physician, often within 24 to 48 hours. We work with clinics across Kentucky to simplify the physician matching process while supporting CAPA-NS and CAPA-CS documentation, KBN portal notifications, quarterly meeting tracking, and long-term collaboration needs.
Final Thoughts
Kentucky collaborating physician requirements are built around a dual-agreement structure that separates nonscheduled and controlled substance prescribing into distinct legal instruments with distinct obligations. The CAPA-NS governs the early career period for nonscheduled prescribing and expires after four years. The CAPA-CS governs controlled substance prescribing with more intensive requirements, including the quarterly KASPER review meetings, the standardized form mandate, the employment condition, and the immediate-cessation rule when the arrangement ends.
For physicians entering the Kentucky market, the most important steps are confirming specialty comparability with the APRN’s practice, using the standardized CAPA-CS form, scheduling and documenting quarterly KASPER meetings from the start of every CAPA-CS, and ensuring the APRN understands the no-grace-period rule for controlled substance prescribing when the CAPA-CS ends.
Build a Compliant Kentucky Collaboration With Collaborating Physician
Are you looking for a collaborating physician role in Kentucky? If you are a licensed Kentucky 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 Kentucky and 50-plus other states. Every arrangement is built to meet state-specific requirements, including Kentucky’s CAPA-NS and CAPA-CS framework under KRS § 314.042, the standardized CAPA-CS form requirement, the same or similar specialty standard, the quarterly KASPER review meeting obligation, the employment condition for controlled substance prescribing, and the KBN portal notification requirements. 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 Kentucky clinics with qualified, vetted collaborating physicians whose specialty aligns with the APRN’s practice area, who are prepared to fulfill the quarterly KASPER review meeting obligation, and who understand the no-grace-period rule for controlled substances when a CAPA-CS ends. Whether you are launching a new clinic, replacing a physician mid-arrangement without a controlled substance grace period, or approaching the four-year CAPA-CS independence milestone, 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. Kentucky healthcare regulations change frequently. Always verify current requirements directly with the Kentucky Board of Nursing, the Kentucky Board of Medical Licensure, and a qualified healthcare attorney before making any practice decisions.
Frequently Asked Questions
Does a Kentucky APRN need a collaborating physician to prescribe nonscheduled drugs?
Yes, for the first four years of the APRN’s prescribing career. The CAPA-NS (Collaborative Agreement for the Advanced Practice Registered Nurse’s Prescriptive Authority for Nonscheduled Legend Drugs) is required under KRS § 314.042(12) before an APRN may prescribe nonscheduled legend drugs. After four years of prescribing with a CAPA-NS in good standing, the APRN may notify the KBN and discontinue the agreement.
What is the difference between a CAPA-NS and a CAPA-CS in Kentucky?
The CAPA-NS governs nonscheduled (non-controlled) prescription drug prescribing for the first four years of an APRN’s prescribing career. The CAPA-CS governs controlled substance prescribing and has additional requirements including a standardized form, quarterly KASPER review meetings with the physician, a DEA and KASPER registration requirement, and an employment condition. The CAPA-CS has no grace period when it ends; the APRN must immediately cease controlled substance prescribing.
How often must a Kentucky physician meet with an APRN who has a CAPA-CS?
At least quarterly. The physician and APRN must meet at least four times per year to review the APRN’s reverse KASPER report or current PDMP data. Each meeting must be documented with the date, a summary of discussions, and any recommendations. Both parties must retain these records for one year past the expiration of the CAPA-CS. Both the KBN and the KBML may audit these records.
Does a Kentucky collaborating physician need to use a specific form for a CAPA-CS?
Yes. Under KRS § 314.042, the standardized CAPA-CS form shall be used by all APRNs and all physicians in Kentucky who enter into a CAPA-CS. A custom or modified form does not satisfy the statutory requirement. The standardized form is available through the Kentucky Board of Nursing.
Can a Kentucky APRN continue prescribing controlled substances if the CAPA-CS ends unexpectedly?
No. There is no grace period for controlled substance prescribing when a CAPA-CS terminates unexpectedly. The APRN must cease prescribing controlled substances immediately until a new CAPA-CS is entered into or the CAPA-CS is resumed. This is a critical distinction from the CAPA-NS, which provides a 30-day grace period for nonscheduled prescribing when that agreement ends unexpectedly.
What is the same or similar specialty requirement in Kentucky?
Under 201 KAR 20:057, both the CAPA-NS and CAPA-CS require the collaborating physician to hold an active Kentucky license in a same or similar specialty to the APRN. The board evaluates comparability based on the facts of the specific situation and the scope of each party’s actual practice. A family medicine physician collaborating with a family NP satisfies the standard clearly. More specialized arrangements require closer analysis of the actual clinical overlap between the physician’s practice and the APRN’s patient population.
