Hawaii collaborating physician requirements reflect a full-practice-authority state for nurse practitioners paired with one of the most procedurally detailed physician assistant supervision frameworks in the country. Hawaii grants full practice authority to nurse practitioners, meaning NPs may practice independently without physician supervision or collaborative agreements, provided all licensure and regulatory requirements are met. For physician assistants, Hawaii Revised Statutes § 453-5.3 and the implementing rules at Hawaii Administrative Rules Title 16, Chapter 85, Subchapter 6 establish a supervision model built around a tiered, experience-based chart review schedule that is unusually specific compared to most other states.
For physicians in Hawaii, the active collaboration framework is found entirely in the PA supervision space, where the degree of record review required shifts predictably as the PA gains practice experience, and where a separate, heightened review standard applies specifically to controlled substance prescriptions. This guide covers every requirement a physician needs to understand in 2026.
Hawaii Collaborating Physician Overview: Where Hawaii Stands
Hawaii is classified as a full-practice-authority state for nurse practitioners. The Hawaii Board of Nursing is the sole regulatory body overseeing nurse practitioner licensing, practice, and discipline in the state, with rules published in Hawaii Administrative Rules Chapter 16-89 and Hawaii Revised Statutes Chapter 457. The Hawaii Medical Board, operating under the Department of Commerce and Consumer Affairs, governs physician licensure and physician assistant certification and supervision requirements under Hawaii Revised Statutes § 453-5.1 and § 453-5.3 and Hawaii Administrative Rules Title 16, Chapter 85, Subchapter 6.
NP Practice Authority in Hawaii: Full Independence Under HRS Chapter 457
Hawaii NPs may practice independently without physician supervision or collaborative agreements, provided all licensure and regulatory requirements are met. A licensed Hawaii APRN may independently assess and diagnose patients, order and interpret diagnostic tests, prescribe legend drugs and pharmacologic treatments, prescribe Schedule II through V controlled substances with a valid DEA registration, and operate in any practice setting consistent with their certification.
Institutional Privileging Is Not a State Mandate
Initial practice for a Hawaii NP may be subject to institutional privileging or specific employer policies, but these are not state mandates. A hospital or health system may impose its own credentialing or oversight expectations on NPs as a matter of internal policy, but Hawaii state law itself imposes no physician collaboration requirement on NP practice or prescribing at any career stage.
Telehealth-Specific Prescribing Rule
Hawaii law explicitly permits telehealth services for nurse practitioners, but prescribing controlled substances via telehealth falls under the scrutiny of both state law under HRS § 457-8.6 and federal law. An initial in-person evaluation is generally required before prescribing Schedule II through IV medications remotely. This is a prescribing-method compliance requirement, not a physician collaboration requirement, and it applies to the NP’s own clinical practice rather than creating any oversight obligation involving a physician.
Hawaii’s Non-Participation in the NLC and APRN Compact
Hawaii is not part of the Nurse Licensure Compact or the APRN Compact. Out-of-state NPs must obtain Hawaii-specific APRN licensure before practicing in the state, and no multistate practice privileges are available for NPs in Hawaii. While this is a licensure portability issue rather than a physician collaboration issue, it is an important practical consideration for any NP relocating to Hawaii or providing interstate telehealth services to Hawaii patients, since full practice authority does not eliminate the separate requirement to hold a Hawaii-specific license.
Where Physician Collaboration Applies: The PA Framework Under HRS § 453-5.3
Active statutory physician collaboration requirements in Hawaii apply to physician assistants. Under HRS § 453-5.3, the Hawaii Medical Board requires each person practicing medicine under the supervision of a physician, osteopathic physician, or group of physicians to be licensed as a physician assistant. A person trained to perform only a very limited number of diagnostic or therapeutic procedures under physician direction is not deemed a practitioner of medicine and does not require PA licensure.
The Statutory Definition of Supervising Physician
Under Hawaii Administrative Rules § 16-85-44.5, a supervising physician means a physician or group of physicians or an osteopathic physician and surgeon licensed to practice medicine and surgery in Hawaii who accepts the responsibility for the supervision of services rendered by physician assistants. The supervising physician shall direct and exercise supervision at all times.
The Statutory Definition of Supervision
Supervision under Hawaii Administrative Rules § 16-85-44.5 means overseeing the activities of, and accepting responsibility for, the medical services rendered by a physician assistant. Hawaii’s rule does not require physical presence as a default condition; the activities of the physician assistant must be overseen, but the supervising physician’s responsibility-acceptance is the operative legal concept rather than physical co-location at every moment of care.
The Supervising Physician Relationship: What Hawaii Law Requires
The PA may perform only those duties and responsibilities delegated by the physician assistant’s supervising physician. The certificate issued by the board recognizes that the applicant is competent to perform, under appropriate supervision, those duties and functions specifically delegated to the applicant by a physician or group of physicians.
Certification Is Tied to an Active Supervisory Relationship
Certification shall be automatically inactivated if the physician assistant is no longer supervised by a physician. This is a structurally important feature of Hawaii’s framework: a PA’s certification is not a standalone credential that persists independent of an active supervisory relationship. If the supervisory relationship ends and is not replaced, the PA’s certification becomes inactive.
No Implication of Independent Practice
PAs must conduct their practice in a manner that does not imply the physician assistant is an independent practitioner. All practice-related activities, including but not limited to making appropriate referrals, must occur within the framework established by the supervising physician or physicians.
The Tiered Chart Review System: Hawaii’s Most Distinctive Feature
Hawaii’s PA supervision framework under HRS § 453-5.3 is unusually specific in defining exactly how many medical records the supervising physician must review and how frequently, based directly on the PA’s accumulated practice experience.
Tier 1: PAs With Less Than One Year of Practice Experience
When supervising a physician assistant with less than one year of practice experience as a licensed physician assistant, the supervising physician, osteopathic physician, or group of physicians shall follow an escalating but declining review schedule:
For the first six months of supervision, the supervising physician must review fifty percent of the medical records within thirty days of the patient visit. For the next six months of supervision, the supervising physician must review twenty-five percent of the medical records within thirty days of the patient visit.
New Specialty Practice May Trigger the Same Standard
The board may, on a case-by-case basis, require physician assistants who begin in a new practice specialty with less than one year of full-time practice experience in that specialty to comply with the same heightened review schedule that applies to PAs newly entering the profession, even if the PA has prior experience in a different specialty area.
Tier 2: PAs With More Than One Year of Practice Experience
When supervising a physician assistant with more than one year of practice experience as a licensed physician assistant, the supervising physician, osteopathic physician, or group of physicians shall establish a process for the regular review of a sample of medical records. This standard is less prescriptive in its specific percentage than the Tier 1 requirement, giving the supervising physician discretion to establish a regular sampling process appropriate to the practice setting and the PA’s demonstrated competency, while still requiring an active, ongoing review mechanism rather than no review at all.
The Controlled Substance Chart Review Requirement
Hawaii imposes an additional, heightened review standard specifically tied to controlled substance prescribing that layers on top of the general record review percentages described above.
For physician assistants who issue controlled substance prescriptions, at least fifty percent of the records reviewed under the applicable Tier 1 or Tier 2 schedule shall include controlled substance prescriptions. If the number of records that include controlled substance prescriptions amounts to less than fifty percent of the records otherwise being reviewed, the supervising physician, osteopathic physician, or group of physicians shall review as many controlled substance prescriptions as are available.
Why This Matters for Physicians
This means a supervising physician cannot satisfy the chart review obligation by reviewing only non-controlled-substance records, even if that would be administratively simpler. If the PA prescribes controlled substances, the physician’s review sample must be weighted so that at least half of the reviewed records involve those prescriptions, subject to the availability exception when the PA’s controlled substance prescribing volume is genuinely too low to reach the fifty percent threshold.
Additional Supervisory Requirements at Any Time
Notwithstanding the tiered schedule described above, a supervising physician, osteopathic physician, or group of physicians may require additional supervisory requirements at any time for patient safety. This gives physicians explicit statutory authority to impose stricter oversight than the statutory minimum whenever they judge it clinically appropriate.
What the Supervisory Guidelines Must Contain
Hawaii’s framework requires written supervisory guidelines establishing the scope of the PA’s practice and the supervision arrangement. These guidelines reflect the degree of supervision appropriate considering the PA’s capabilities and amount of training, the needs of patients in the geographic area where the PA and supervising physician practice, the practice setting, and the varying degrees of supervision and direction appropriate for each area and setting.
Delegated Services Must Match Physician Competency
PAs may only perform medical services delegated by their supervising physicians, and those delegated services must match the physician’s own education, training, and experience. A physician cannot delegate clinical tasks to a PA that fall outside what the physician is themselves qualified to perform.
Where the Guidelines Must Be Kept
The guidelines shall be kept in the office of the practice setting in which either the physician assistant or the supervising physician, osteopathic physician, or group of physicians practices, and shall be made available to the Hawaii Medical Board and the regulated industries complaints office or its designees upon request.
No Pre-Filing Requirement
Hawaii does not require the supervisory guidelines to be submitted to the Hawaii Medical Board for pre-approval before the PA begins practicing. The guidelines must exist, address the required content, and be produced upon request by the board or its complaints office designees.
Physician Eligibility for PA Supervision in Hawaii
A qualifying Hawaii supervising physician must be a physician or osteopathic physician and surgeon licensed to practice medicine and surgery in Hawaii who accepts responsibility for the supervision of services rendered by the physician assistant.
Group Supervision Is Permitted
Hawaii’s statutory definition allows a group of physicians, not only a single named individual, to serve as the supervising entity for a PA. This gives larger practices and institutional settings flexibility in how supervisory responsibility is distributed among multiple physicians.
No Mandatory Physical Presence Requirement
Hawaii’s supervision rules do not impose a default requirement that the supervising physician be physically present at the time and place services are rendered by the PA. The core legal concept is the physician’s acceptance of responsibility and the establishment of the appropriate degree of supervision and direction for the specific practice area and setting, which can include oversight that does not require constant physical co-location.
The Board’s Authority to Require Additional Supervision
Beyond the tiered chart review schedule, the Hawaii Medical Board retains broad rulemaking authority. The board shall establish the application procedure, medical educational and training standards, examination requirement if any, and degrees of supervision by rule. This means the specific degree-of-supervision standards can be further refined through board rulemaking beyond the baseline statutory tiers described in this guide, and physicians and PAs should confirm current Hawaii Administrative Rules for any updates to these standards.
Prescriptive Authority and Controlled Substances for Hawaii PAs
The Schedule II Restriction
Hawaii PAs may prescribe medications, devices, and Schedule III through V controlled substances, but may not prescribe Schedule II controlled substances. This is a hard statutory and regulatory limitation that does not vary based on the PA’s years of experience or the content of the supervisory agreement; Schedule II prescribing authority is not extended to PAs in Hawaii under current law.
Schedule II Prescribing and Administering Distinction
Under Hawaii Administrative Rules § 23-200-14, a physician assistant, in good faith and in the course of professional practice only, may prescribe or administer a controlled substance under the authority and supervision of the supervising physician as designated under HRS § 329-38. Physicians should confirm the specific scheduling limitations that apply, since the prescribing restriction for Schedule II substances is a defining feature of the Hawaii PA scope.
Written Agreement for Prescriptive Privileges
State law requires a written agreement between PAs and supervising physicians outlining their prescribing privileges. The supervising physician determines the types of medications the PA may prescribe, with that prescriptive authority specifically outlined in the written supervisory agreement or guidelines.
The Dual DEA Number Requirement on Prescriptions
Hawaii imposes a distinctive prescription format requirement for PA-issued controlled substance prescriptions under HRS § 329-38.
Both DEA Numbers Must Appear
A physician assistant registered to prescribe controlled substances under the authorization of a supervising physician shall include on all controlled substance prescriptions issued both the DEA registration number of the supervising physician and the DEA registration number of the physician assistant. This dual-DEA-number requirement is more specific than the prescription format rules in most other states covered in this series, where typically only the prescribing PA’s own credentials are required on the face of the prescription.
Additional Prescription Content Requirements
Each written controlled substance prescription issued must also include the printed, stamped, typed, or hand-printed name, address, and phone number of both the supervising physician and the physician assistant, and must be signed by the physician assistant.
Schedule II Quantity Limit
Separately from the PA-specific Schedule II prescribing restriction, Hawaii law generally limits Schedule II narcotic controlled substance prescriptions to no more than a thirty-day supply, except in specific circumstances such as single unit dose packaging or terminally ill patient certifications. This quantity limit applies to physician prescribing generally and is relevant context for any physician who also personally manages controlled substance prescribing within a practice that includes supervised PAs.
Common Compliance Mistakes Hawaii Collaborating Physicians Make
Physicians sometimes apply a flat, uniform chart review percentage regardless of the PA’s experience level. Hawaii’s tiered schedule requires fifty percent review in the first six months, twenty-five percent in the next six months, and a regular sampling process after one year. A supervising physician using the same review rate throughout a new PA’s first year is not following the statutory schedule.
The controlled substance review weighting is sometimes overlooked. Even where a general chart review percentage is being correctly followed, the requirement that at least fifty percent of those reviewed records include controlled substance prescriptions, when the PA issues such prescriptions, is a separate and additional standard that must be satisfied.
Physicians sometimes omit their own DEA number from PA-issued controlled substance prescriptions. Hawaii’s dual DEA number requirement means both the supervising physician’s and the PA’s DEA registration numbers must appear on the prescription. A prescription bearing only the PA’s DEA number does not meet HRS § 329-38.
Physicians occasionally assume Schedule II prescribing can be authorized through the supervisory agreement. Hawaii does not permit PAs to prescribe Schedule II controlled substances regardless of what the supervisory guidelines state; this is a fixed statutory and regulatory limitation, not a negotiable scope element.
Supervisory guidelines are sometimes not updated or are kept only at one location when the PA practices in multiple settings. The guidelines must be kept in the office of the practice setting where either party practices and must be available to the board or complaints office on request; physicians supervising PAs across multiple sites should ensure guidelines are accessible at each relevant location.
Hawaii Collaborating Physician Requirements: Quick Reference
NP Practice Authority
Hawaii is a full-practice-authority state for nurse practitioners. No physician collaboration agreement is required for NP practice or prescribing. Institutional privileging requirements, where they exist, are employer policy rather than state mandate. Hawaii does not participate in the NLC or APRN Compact, so out-of-state NPs need Hawaii-specific licensure.
PA Supervision Framework (Active Requirement)
Every PA must practice under an active supervising physician or group of physicians; certification is automatically inactivated if supervision ends. Supervising physician accepts responsibility for the PA’s services and must direct and exercise supervision at all times.
Tiered Chart Review Schedule
Less than one year of PA experience: fifty percent of records reviewed within thirty days for the first six months; twenty-five percent for the next six months. More than one year of PA experience: regular review of a sample of medical records, frequency determined by the supervising physician. Board may apply the less-than-one-year standard to new specialty practice on a case-by-case basis.
Controlled Substance Review Standard
At least fifty percent of reviewed records must include controlled substance prescriptions when the PA issues them, subject to an availability exception if volume is too low to reach that threshold.
Supervisory Guidelines
Must reflect PA capability and training, patient needs in the geographic area, practice setting, and appropriate degree of supervision. Kept at the practice location; produced to the Hawaii Medical Board or regulated industries complaints office upon request. No pre-filing requirement.
Prescriptive Authority
PAs may prescribe Schedule III through V controlled substances; Schedule II is not authorized for PAs under current Hawaii law. Both the supervising physician’s and the PA’s DEA numbers must appear on all controlled substance prescriptions, along with both parties’ printed name, address, and phone number.
Physician Eligibility
Active Hawaii MD, DO, or osteopathic physician and surgeon license. May supervise individually or as part of a group of physicians. No mandatory constant physical presence requirement; physician may impose additional supervisory requirements at any time for patient safety.
Clinics Also Need to Understand Hawaii Collaboration Requirements
While this guide primarily covers the physician collaboration framework in Hawaii, these regulations directly affect PA-operated clinics and healthcare practices that depend on physician supervision. NP-operated clinics in Hawaii do not require physician collaboration under state law. PA-operated clinics or clinics that employ PAs must maintain an active supervising physician relationship at all times, since the PA’s certification becomes inactive the moment that relationship lapses.
Need Help Finding a Hawaii Collaborating Physician?
For clinics with PA providers, the next challenge is finding a qualified Hawaii-licensed physician who is prepared to follow the tiered chart review schedule for newer PAs, weight that review appropriately when the PA prescribes controlled substances, and maintain written supervisory guidelines specific to the clinic’s practice setting and the PA’s delegated scope. Whether you are launching a new PA-operated clinic, onboarding a PA who is new to a specialty area, or ensuring your existing supervisory guidelines reflect current delegated services, having the right physician relationship in place matters.
If your clinic is actively looking for a Hawaii collaborating physician, our team can match you with a qualified physician, often within 24 to 48 hours. We work with clinics across Hawaii to simplify the physician matching process while supporting supervisory guideline drafting, chart review schedule compliance, and long-term collaboration needs.
Final Thoughts
Hawaii collaborating physician requirements reflect a state that has fully resolved the NP collaboration question through full practice authority while building one of the most procedurally specific PA supervision frameworks among the states in this series. The tiered chart review schedule, the additional controlled substance review weighting, the dual DEA number prescription requirement, and the automatic certification inactivation upon loss of supervision all create a compliance environment that rewards careful, ongoing attention rather than a one-time supervisory agreement signature.
For physicians entering the Hawaii PA supervision market, the most important steps are following the correct chart review percentage for the PA’s experience tier, ensuring controlled substance prescriptions receive the required proportional review, including both DEA numbers on every controlled substance prescription, and keeping written supervisory guidelines current and accessible at every practice location where the PA provides care.
Build a Compliant Hawaii Collaboration With Collaborating Physician
Are you looking for a collaborating physician role in Hawaii? If you are a licensed Hawaii physician interested in a structured, compliant PA supervisory arrangement, Collaborating Physician handles the infrastructure so you do not have to figure it out alone. The platform connects licensed physicians with vetted clinics across Hawaii and 50-plus other states. Every arrangement is built to meet state-specific requirements, including Hawaii’s tiered chart review schedule under HRS § 453-5.3, the controlled substance review weighting standard, the dual DEA number prescription format requirement, the Schedule II prescribing restriction for PAs, and the written supervisory guidelines content and retention rules. 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 Hawaii clinics with qualified, vetted supervising physicians who understand the tiered chart review obligations for newer PAs, are prepared to weight controlled substance prescription review correctly, and will maintain compliant written supervisory guidelines specific to your practice setting. Whether you are launching a new PA-operated clinic, onboarding a PA into a new specialty area, or replacing a supervising physician whose relationship with your PA has ended, 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. Hawaii healthcare regulations change frequently. Always verify current requirements directly with the Hawaii Board of Nursing, the Hawaii Medical Board, and a qualified healthcare attorney before making any practice decisions.
Frequently Asked Questions
Does a Hawaii NP need a collaborating physician?
No. Hawaii grants full practice authority to nurse practitioners, meaning NPs may practice independently without physician supervision or collaborative agreements, provided all licensure and regulatory requirements are met. Institutional privileging or employer policies may add expectations, but these are not state-law mandates.
Do Hawaii PAs need a collaborating physician?
Yes. Under HRS § 453-5.3, every PA must practice under the supervision of a physician, osteopathic physician, or group of physicians who accepts responsibility for the PA’s services. A PA’s certification is automatically inactivated if the physician assistant is no longer supervised by a physician.
How often must a Hawaii supervising physician review a new PA’s medical records?
For a PA with less than one year of practice experience, the supervising physician must review fifty percent of the medical records within thirty days of the patient visit for the first six months of supervision, then twenty-five percent of the medical records within thirty days for the next six months. After the PA has more than one year of experience, the physician establishes a regular process for reviewing a sample of medical records.
Does Hawaii require extra chart review for PAs who prescribe controlled substances?
Yes. For physician assistants who issue controlled substance prescriptions, at least fifty percent of the records reviewed under the applicable schedule must include controlled substance prescriptions, unless the PA’s controlled substance prescribing volume is too low to reach that threshold, in which case the physician reviews as many controlled substance records as are available.
Can Hawaii PAs prescribe Schedule II controlled substances?
No. Hawaii PAs may prescribe medications, devices, and Schedule III through V controlled substances, but Schedule II controlled substances are not within the PA’s authorized prescribing scope under current Hawaii law.
What must appear on a Hawaii PA’s controlled substance prescription?
Under HRS § 329-38, the prescription must include the DEA registration number of both the supervising physician and the physician assistant, along with the printed, stamped, typed, or hand-printed name, address, and phone number of both parties, and must be signed by the physician assistant.
