Delaware collaborating physician requirements apply to a full-practice-authority state that uses a time-and-hours-based transitional period to gate independent practice for newly licensed APRNs. Delaware adopted full practice authority in 2021 through legislation that removed the collaborative agreement as a requirement for APRN licensure. However, every APRN who has not yet completed two years and 4,000 hours of collaborative clinical practice must maintain a written collaborative agreement before beginning clinical work, and that agreement must be in place for prescriptive authority purposes.
For physicians in Delaware, the collaboration framework is active and meaningful during the APRN’s early-career period and creates a defined documentation trail that ultimately supports the APRN’s application for independent practice approval from the Delaware Board of Nursing’s APRN Committee. This guide covers every requirement a physician needs to understand in 2026, sourced directly from Title 24 of the Delaware Code, Chapter 19, and Delaware Administrative Code 24-1900.
Delaware Collaborating Physician Overview: Where Delaware Stands
Delaware is classified as a full-practice-authority state by the American Association of Nurse Practitioners. Delaware Code Title 24, § 1935(b) grants licensed APRNs full-practice authority including the right to prescribe, procure, administer, and dispense legend and controlled substances within the APRN’s role and population foci.
Governing Body
The Delaware Board of Nursing governs APRN licensure, collaborative agreement requirements, the APRN Committee’s independent practice approval process, and disciplinary matters under Title 24 Chapter 19 and Delaware Administrative Code 24-1900. The Delaware Office of Controlled Substances, through the Delaware Division of Professional Regulation, governs controlled substance registrations for APRNs.
The 2021 Legislative Change
Delaware HB 141, enacted in 2021, fundamentally restructured APRN practice in Delaware by removing the collaborative agreement as a requirement for APRN licensure. An APRN may now obtain a Delaware APRN license without having a collaborative agreement in place. However, the same legislation preserved the 2-year/4,000-hour collaborative practice requirement as the threshold for independent practice. APRNs who do not yet meet that threshold must have a collaborative agreement in place before beginning clinical work and before obtaining prescriptive authority.
The Broader Definition of Collaborative Partners in Delaware
One of the most distinctive features of Delaware’s framework is the broad definition of who may serve as the collaborative partner for an APRN. Under Title 24, Chapter 19, a collaborative agreement is defined as a written document expressing an arrangement between a licensed physician, podiatrist, or licensed Delaware health care delivery system and an advanced practice registered nurse.
What This Means
Delaware is one of a small number of states that explicitly allows a licensed health care delivery system to be the party to a collaborative agreement rather than a named individual physician. A hospital, a health system, a clinic organization, or another licensed Delaware health care delivery system may enter into the collaborative agreement as the institutional party.
Additionally, the Delaware Board of Nursing’s guidance and current administrative code have been updated to recognize that experienced APRNs may also serve as the collaborative party for new APRNs in some circumstances. An APRN applying for prescriptive authority who has not had independent prescriptive authority within the past two years may satisfy the requirement through a collaborative agreement with a physician or with an experienced APRN.
The Two-Tier Practice Framework
Delaware’s practice framework for APRNs operates in two tiers based on clinical experience.
Tier 1: Collaborative Practice (Under 2 Years or 4,000 Hours)
An APRN who has not completed at least two years and 4,000 hours of collaborative clinical practice must operate under a collaborative agreement before beginning clinical work. For prescriptive authority, the collaborative agreement must be in place along with the completion of required pharmacology coursework.
Tier 2: Independent Practice (After 2 Years and 4,000 Hours)
An APRN who has completed the 2-year and 4,000-hour requirement may apply to the APRN Committee for independent practice authority. Independent practice in Delaware is defined specifically as practice and prescribing by an APRN who is not subject to a collaborative agreement and works outside the employment of an established health care organization, health care delivery system, physician, podiatrist, or practice group owned by a physician or podiatrist. Independent practice must be in an area substantially related to the population focus of the APRN’s education and certification.
The Critical Distinction Within Tier 2
APRNs who work within an established health care organization or health care delivery system do not need to obtain formal independent practice approval from the APRN Committee to practice without a personal physician collaborative agreement. The institutional employment relationship itself functions as the structural oversight context. Independent practice approval is specifically required for APRNs who wish to practice entirely outside an organizational or physician-affiliated structure.
The Collaborative Agreement: Delaware’s Core Compliance Document
Under Title 24, § 1935 and Delaware Administrative Code 24-1900-8.0, all new APRN graduates and APRNs seeking to obtain independent practice must operate under a collaborative agreement before beginning clinical work. The collaborative agreement is the written document that governs the APRN’s practice during the transition period toward independent authority.
The Agreement Must Be in Place Before Clinical Work Begins
An APRN can obtain a Delaware APRN license without a collaborative agreement in place. However, clinical work, including any patient assessment, diagnosis, treatment, or prescribing, cannot begin until a collaborative agreement is executed. The agreement is a prerequisite for clinical practice, not for licensure.
The Agreement Covers Each Employer
An APRN who works for more than one practice or business must have a separate collaborative agreement for each. If a single practice has more than one location, however, a single collaborative agreement covers all locations of that practice. The agreement is employer-specific, not location-specific.
No Prior Board Approval Required
Delaware does not require the collaborative agreement to be submitted to the Board of Nursing for pre-approval before clinical work begins. The agreement is maintained by both parties and must be submitted to the APRN Committee as part of the independent practice application when the APRN applies for independent practice approval.
What the Delaware Collaborative Agreement Must Establish
Under Title 24, Chapter 19, and Delaware Administrative Code 24-1900, the collaborative agreement must address how the physician and APRN will cooperate, coordinate, and consult with each other in the provision of health care to their patients pursuant to Board of Nursing rules. The agreement must address, at minimum:
1. Cooperation and Coordination in Patient Care
The agreement must describe how the physician and APRN will cooperate and coordinate in providing health care to patients. This includes describing the nature of the working relationship, the clinical environment, and how clinical decisions will be made collaboratively.
2. Consultation Process
The agreement must describe how the APRN will consult with the physician when patient care situations exceed the APRN’s expertise or require physician involvement. The method and availability of consultation must be documented.
3. Population Focus Alignment
The physician, podiatrist, or health care delivery system party to the collaborative agreement must practice in an area substantially related to the population focus of the APRN’s education, certification, and planned independent practice. The alignment must be genuine and documented in the agreement’s description of the collaborative relationship.
4. Planning for Management of Situations Beyond the APRN’s Expertise
The agreement must address how situations beyond the APRN’s expertise will be managed, including consultation and referral pathways.
5. Consultation and Referral to Other Providers
The agreement must address how the APRN will consult with and refer to other health care providers as appropriate when patient needs exceed the scope of the collaborative arrangement.
The 2-Year and 4,000-Hour Experience Requirement
The experience threshold for independent practice in Delaware is defined by both time and hours. Under Title 24, § 1935 and the HB 141 framework:
- The APRN must have practiced under a collaborative agreement for at least two years, AND
- A minimum of 4,000 full-time hours
Both conditions must be met. An APRN who has accumulated 4,000 hours in less than two years does not satisfy the requirement. An APRN who has practiced for two years but has not yet reached 4,000 hours does not satisfy the requirement.
Where the Practice Must Occur
The 4,000 hours of collaborative practice must occur within a hospital or integrated clinical setting where APRNs and physicians work together to provide patient care. This is not a general clinical experience requirement. Delaware specifically requires that the qualifying hours be accumulated in an institutional or integrated setting with physician-APRN co-practice, not in a standalone independent clinic.
The Physician’s Role in Documentation
The collaborative agreement that covers the 4,000-hour period must be submitted to the APRN Committee as part of the independent practice application. The physician who was party to the collaborative agreement is documenting, through that agreement, that the APRN practiced under a qualifying collaborative arrangement during the required period.
The Independent Practice Application: What the APRN Committee Reviews
When an APRN has met both thresholds, the APRN applies to the Delaware Board of Nursing’s APRN Committee for independent practice approval.
What the Committee Evaluates
The Committee evaluates evidence that the APRN has:
- Practiced under a collaborative agreement within a hospital or integrated clinical setting for at least 2 years and a minimum of 4,000 full-time hours
- A collaborative agreement that was with a physician, podiatrist, or health care delivery system practicing in an area substantially related to the APRN’s population focus
The Committee makes a recommendation to the Delaware Board of Nursing, which issues the formal independent practice approval. Until that approval is granted, the APRN must maintain the collaborative agreement.
After Independent Practice Approval
Once independent practice is approved by the Board of Nursing, the APRN may practice and prescribe without a collaborative agreement as long as the APRN is working outside the employment of a health care organization, health care delivery system, physician, podiatrist, or practice group owned by a physician or podiatrist. APRNs who are independently approved but remain employed within a health system or physician-owned practice are not practicing in the independent practice mode and are not subject to the same documentation requirements as truly independent APRNs.
Physician Eligibility: The Population Focus Alignment Standard
A qualifying Delaware collaborating physician must hold a current, active Delaware medical license in good standing. The physician must practice in an area substantially related to the population focus of the APRN’s education, certification, and planned independent practice.
The Substantial Relationship Standard
Delaware’s population focus alignment standard is purpose-driven. The collaborative agreement must be with a physician whose practice gives the APRN meaningful clinical grounding in the patient population they serve and will independently serve. A family medicine physician collaborating with a family health NP satisfies this standard clearly. A physician whose specialty has no relationship to the APRN’s population focus does not.
A Health Care Delivery System Can Serve as the Collaborative Party
In Delaware, the collaborative partner does not have to be a named individual physician. A licensed Delaware health care delivery system may execute the collaborative agreement as the institutional party. For APRNs working within hospitals, academic health centers, or multi-specialty clinical organizations, the institution itself may be the collaborative partner rather than a specific physician.
No Geographic Proximity Requirement
Delaware does not impose a geographic proximity requirement on collaborating physicians. The physician does not need to practice near the APRN’s clinical location. The collaborative relationship may be conducted in person or through telecommunications as the clinical situation requires.
No Ratio Limit
Delaware does not impose a statutory cap on the number of APRNs a physician may collaborate with simultaneously.
Multiple Practice Locations and Multi-Employer Agreements
Delaware’s agreement structure creates specific requirements when an APRN works in more than one setting.
One Agreement Per Employer
An APRN working for multiple employers must have a separate collaborative agreement for each employer. A single agreement with one physician does not cover clinical work at a separate, unaffiliated practice. Each employer relationship requires its own collaborative agreement.
One Agreement Covers All Locations of a Single Practice
If a single practice operates across multiple physical locations, one collaborative agreement covers all of those locations. The physician does not need to sign a separate agreement for each branch of the same practice organization.
Prescriptive Authority During the Collaborative Period
During the collaborative period, APRNs in Delaware may prescribe legend drugs and Schedule II through V controlled substances within their role and population foci under Title 24, § 1935(b)(1).
The Prescriptive Authority Condition for New Prescribers
Under Delaware Administrative Code 24-1900, an NP who has not had independent prescriptive authority within the past two years in Delaware or in any other state must, in addition to having a collaborative agreement, complete 30 hours of advanced pharmacology before obtaining prescriptive authority.
This condition applies to new APRN graduates entering prescribing for the first time and to APRNs who have been inactive for two or more years. An APRN who has held active prescriptive authority in any state within the past two years is not subject to the 30-hour requirement when seeking Delaware prescriptive authority.
The 30-Hour Advanced Pharmacology Requirement
For APRNs applying for prescriptive authority who have not held active prescriptive authority in the past two years, Delaware Administrative Code § 4-8.18 requires completion of 30 hours of advanced pharmacology coursework in addition to the collaborative agreement.
What This Means for Physicians
A physician entering a collaborative agreement with a new Delaware APRN who has not previously held prescriptive authority should understand that the prescriptive authority component of the collaborative arrangement cannot begin until the 30-hour pharmacology requirement is satisfied. Clinical practice under the collaborative agreement may begin, but prescribing cannot begin until both the collaborative agreement and the pharmacology documentation are in place and accepted by the Board.
Controlled Substance Registration: The Two-Step Delaware Process
Delaware’s controlled substance prescribing process involves two separate registrations, both of which must be obtained before any controlled substance is prescribed.
Step 1: Delaware Controlled Substance Registration (CSR)
The APRN must obtain a Delaware Controlled Substance Registration through the Delaware Office of Controlled Substances via the DELPROS online portal. The CSR application requires documentation of prescriptive authority and, for APRNs in the collaborative period, evidence of the active collaborative agreement.
Step 2: DEA Registration for Delaware
After receiving the Delaware CSR, the APRN must then apply for a federal DEA registration specifically for Delaware. A DEA registration issued in any other jurisdiction is not sufficient for prescribing controlled substances in Delaware. The DEA registration must be applied for separately and must cover Delaware.
Both Must Be in Place Before Prescribing
Under Delaware law and Division of Professional Regulation guidance, the APRN must hold both an active Delaware CSR and a Delaware DEA registration before prescribing any controlled substance. Prescribing without both registrations in place is a compliance violation from the first prescription written.
The 72-Hour Dispensing Limit
Delaware imposes a specific limit on the dispensing of controlled substances by APRNs. Under the Delaware Controlled Substances Act and Division of Professional Regulation rules, an APRN may dispense no more than a 72-hour supply of controlled substances.
The PMP Reporting Requirement
If an APRN dispenses the maximum 72-hour supply, the APRN must report to the Delaware Prescription Monitoring Program (PMP). This reporting requirement applies specifically to the act of dispensing, not simply prescribing. Prescribing a written prescription that a patient fills at a pharmacy is not subject to the 72-hour dispensing limit. Dispensing means providing the medication directly from the clinical setting.
PA Collaboration Requirements and CSR Reporting Obligations
Physician assistants in Delaware are not governed by the APRN collaborative agreement framework. PAs in Delaware must maintain a supervising physician relationship for controlled substance registration purposes.
The PA CSR Process
Under the Delaware Division of Professional Regulation’s PA Controlled Substance Registration guidance, a PA must identify a supervising physician for each individual business or practice where the PA will prescribe controlled substances in Delaware. The PA must report the supervising physician’s information as part of the CSR application through DELPROS.
Reporting Changes
If a PA’s collaborating physician changes, including additions of new collaborators or departures of existing ones, the PA must submit a Collaborating Physician Change Service Request through DELPROS. This reporting obligation applies even when the PA does not need a new or additional CSR for the new practice location.
The 72-Hour Dispensing Limit for PAs
The same 72-hour controlled substance dispensing limit that applies to APRNs applies equally to PAs. A PA may dispense no more than a 72-hour supply and must report to the Delaware PMP when dispensing the maximum supply.
Common Compliance Mistakes Delaware Collaborating Physicians Make
Most Delaware collaborative agreement compliance problems involve population focus mismatches, the multi-employer agreement requirement, and misunderstanding the sequential structure of the prescribing authority pathway.
- Population focus not substantially related between physician and APRN. The collaborative agreement party must practice in an area substantially related to the APRN’s population focus. A physician whose clinical background has no meaningful connection to the APRN’s practice population does not satisfy the standard and cannot support a qualifying independent practice application.
- APRN begins clinical work before the agreement is executed. The collaborative agreement must be in place before the APRN begins any patient assessment, diagnosis, treatment, or prescribing. An APRN who begins clinical work immediately after licensure, before signing the agreement, is practicing without the required structure.
- One agreement used for multiple unrelated employers. An APRN working at two separate practices needs a separate collaborative agreement for each. A physician who signs one agreement covering the APRN’s work at two independent practices is not providing the employer-specific agreement structure Delaware requires.
- APRN begins prescribing before the 30-hour pharmacology requirement is satisfied. For new prescribers without prior active prescriptive authority in the past two years, prescribing cannot begin until both the collaborative agreement is in place and the 30-hour advanced pharmacology documentation is submitted. A physician who assumes prescribing begins immediately after signing the agreement may be wrong about when the APRN is authorized to prescribe.
- CSR obtained without DEA registration in Delaware. The APRN must hold both a Delaware CSR and a Delaware-specific DEA registration before prescribing any controlled substance. A DEA registration from another state does not cover Delaware. Physicians should confirm with their APRNs that both registrations are active before any controlled substance prescribing begins.
- Collaborative agreement not submitted with the independent practice application. When the APRN applies for independent practice, the collaborative agreement from the qualifying period must be submitted to the APRN Committee as evidence of the 2-year/4,000-hour requirement. Physicians who do not maintain copies of their collaborative agreements may create practical obstacles for the APRN’s independence application.
Delaware Collaborating Physician Requirements: Quick Reference
Practice Authority Framework
- Delaware is a full-practice-authority state for APRNs under Title 24, § 1935(b)
- APRNs may be licensed without a collaborative agreement, but must have one before beginning clinical work if they have not met the 2-year/4,000-hour threshold
- Independent practice (outside health care organizations): requires APRN Committee approval after 2 years and 4,000 hours of collaborative practice
Collaborative Agreement Definition
- Written document between an APRN and a licensed physician, podiatrist, OR licensed Delaware health care delivery system
- Must be in place before clinical work begins for APRNs without the 2-year/4,000-hour threshold
Collaborative Agreement Content
- Must address cooperation and coordination in patient care, consultation process, population focus alignment, management of situations beyond APRN expertise, and referral pathways
- Physician, podiatrist, or health care delivery system must practice in area substantially related to APRN’s population focus
The 2-Year and 4,000-Hour Requirement
- Minimum 2 years AND 4,000 full-time hours of collaborative practice
- Must occur within a hospital or integrated clinical setting where APRNs and physicians work together
- Submitted to APRN Committee with independent practice application
Multi-Employer Agreement Requirement
- Separate collaborative agreement required for each employer
- Single practice with multiple locations covered by one agreement
Prescriptive Authority
- Schedule II through V authorized during collaborative period
- APRNs without active prescriptive authority in the past two years must complete 30 hours of advanced pharmacology
- Delaware CSR and Delaware DEA registration both required before prescribing controlled substances
- 72-hour dispensing limit; PMP reporting required at maximum supply
Physician Eligibility
- Active, unencumbered Delaware MD or DO license
- Must practice in area substantially related to APRN’s population focus
- Health care delivery system may serve as collaborative partner
- No geographic proximity requirement; no ratio limit
Clinics Also Need to Understand Delaware Collaboration Requirements
While this guide primarily covers the physician collaboration requirements in Delaware, these regulations directly affect APRN-operated clinics, medspas, and healthcare practices that depend on physician collaboration during the early-career period. In many cases, clinic owners researching Delaware collaboration rules are trying to understand how to find a qualified physician whose practice is substantially related to the APRN’s population focus, who can execute a compliant employer-specific collaborative agreement, and who will maintain the documentation needed to support the APRN’s independent practice application.
Need Help Finding a Delaware Collaborating Physician?
For clinics, understanding the legal requirements is only one part of the process. The next challenge is finding a qualified physician or health care delivery system collaborative partner whose population focus aligns with the APRN’s clinical area, who understands that the collaborative agreement must be employer-specific and cannot cover multiple independent practices, and who is prepared to maintain the agreement documentation that will eventually be submitted to the APRN Committee. Whether you are launching a new clinic with a recently licensed APRN, replacing a physician mid-way through the 2-year collaborative period, or ensuring the agreement documentation is sufficient to support the independence application, having the right physician in place matters.
If your clinic is actively looking for a Delaware collaborating physician, our team can match you with a qualified physician, often within 24 to 48 hours. We work with clinics across Delaware to simplify the physician matching process while supporting collaborative agreement drafting, the APRN Committee documentation process, and long-term collaboration needs.
Final Thoughts
Delaware collaborating physician requirements reflect a full-practice-authority state that uses a structured, time-and-hours-based transitional period to ensure newly licensed APRNs accumulate meaningful collaborative clinical experience before practicing independently. The 2-year and 4,000-hour threshold, the hospital or integrated setting requirement, the population focus alignment standard, and the employer-specific agreement structure create a compliance framework that is specific, documentable, and directly tied to the APRN’s path to independent practice.
For physicians entering the Delaware market, the most important steps are confirming population focus alignment with the APRN’s clinical area, ensuring the collaborative agreement is employer-specific rather than generic, maintaining the agreement documentation throughout the collaborative period, and understanding the sequential controlled substance registration process that must be completed before any controlled substance prescribing can begin.
Build a Compliant Delaware Collaboration With Collaborating Physician
Are you looking for a collaborating physician role in Delaware? If you are a licensed Delaware physician interested in a structured, compliant collaboration arrangement with an APRN-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 Delaware and 50-plus other states. Every arrangement is built to meet state-specific requirements, including Delaware’s collaborative agreement framework under Title 24 Chapter 19, the population focus alignment standard, employer-specific agreement requirements, the 2-year/4,000-hour qualifying period structure, the 30-hour advanced pharmacology condition for new prescribers, and the two-step Delaware CSR and DEA registration pathway. 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 Delaware clinics with qualified, vetted collaborating physicians whose clinical backgrounds are substantially related to the APRN’s population focus, who understand the employer-specific agreement structure, and who are prepared to maintain the collaborative documentation needed for the APRN’s independent practice application. Whether you are launching a new clinic with a new APRN, managing the midpoint of the 2-year collaborative period, or approaching the independent practice application threshold, 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. Delaware healthcare regulations change frequently. Always verify current requirements directly with the Delaware Board of Nursing, the Delaware Division of Professional Regulation, and a qualified healthcare attorney before making any practice decisions.
Frequently Asked Questions
Does a Delaware APRN need a collaborating physician to practice?
It depends on the APRN’s experience level. An APRN who has not yet completed two years and 4,000 hours of collaborative clinical practice must have a collaborative agreement in place before beginning clinical work, even though Delaware law allows APRN licensure without an agreement. An APRN who has completed the 2-year/4,000-hour requirement and received independent practice approval from the APRN Committee does not need a collaborative agreement.
Who can serve as a collaborative partner for a Delaware APRN?
A Delaware collaborative agreement may be made with a licensed physician, a licensed podiatrist, or a licensed Delaware health care delivery system. Delaware is one of a small number of states that explicitly allows an institutional health care delivery system, rather than a named individual physician, to serve as the collaborative party.
Does the collaborative agreement need to be filed with the Delaware Board of Nursing?
The agreement does not need to be filed with the Board before clinical work begins. However, the agreement must be submitted to the APRN Committee as part of the independent practice application when the APRN applies for independent practice approval after completing the 2-year/4,000-hour requirement.
Can one collaborative agreement cover an APRN’s work at multiple practices?
No. An APRN working for more than one practice or business needs a separate collaborative agreement for each employer. However, a single practice with multiple locations is covered by one agreement.
What additional requirement applies to Delaware APRNs who have not previously held prescriptive authority?
An APRN who has not had active independent prescriptive authority within the past two years in Delaware or any other state must complete 30 hours of advanced pharmacology coursework in addition to having a collaborative agreement before receiving prescriptive authority. This requirement does not apply to APRNs who have held active prescriptive authority within the past two years.
Does a Delaware APRN need a separate DEA registration for Delaware?
Yes. Delaware requires APRNs to obtain both a Delaware Controlled Substance Registration from the Delaware Office of Controlled Substances and a DEA registration specifically for Delaware. A DEA registration from another jurisdiction is not sufficient for prescribing controlled substances in Delaware.
