A New York nurse practitioner may need a collaborating physician, but the answer depends primarily on the NP’s qualifying practice experience. An NP who has not completed 3,600 hours of qualifying practice generally needs a written practice agreement and written practice protocols with a physician qualified in the NP’s specialty. An NP who has completed the experience threshold is exempt from those requirements under the law currently in effect through July 1, 2030.
New York does not classify this arrangement as physician supervision. The New York State Education Department (NYSED) says NPs are independently responsible for diagnosing and treating their patients, including while a written collaboration agreement is required.
This guide explains the 3,600-hour rule, the agreement and chart-review requirements, the four-off-site-NP limit, New York’s fee-splitting restrictions, and typical collaborating physician costs in 2026.
New York Requirements at a Glance
| Question | Current New York rule |
|---|---|
| Does every NP need a collaborating physician? | No. The formal collaboration requirement generally applies until the NP completes 3,600 hours of qualifying practice. |
| What does an NP below 3,600 hours need? | A written practice agreement and written practice protocols with a qualified collaborating physician. |
| What changes after 3,600 hours? | Through July 1, 2030, the NP is not required to maintain physician collaboration, a written practice agreement, or written protocols under Education Law § 6902(3)(b). |
| Must the physician be board-certified in the NP’s specialty? | The statute requires a physician licensed in New York and qualified to collaborate in the specialty involved. It does not state a universal board-certification requirement. |
| How often must records be reviewed? | At least every three months while a written practice agreement is required. New York sets no fixed chart count. |
| Is there an off-site ratio limit? | Yes. One physician may not enter written practice agreements with more than four NPs who are not on the same physical premises. |
| Must the agreement be filed with NYSED in 2026? | No general filing requirement applies under the rule currently in force. A copy must be kept at each practice setting and available for NYSED inspection. |
| Can compensation be based on practice revenue? | Generally no. Percentage-based or revenue-dependent payments can constitute prohibited fee splitting. |
| What does collaboration usually cost? | Current published benchmarks place ordinary arrangements around the mid-$500s per month, with broader market rates often ranging from about $450 to $750. Scope, specialty, workload, and included services can move the price. |
Do You Need a Collaborating Physician in New York?
An NP who has not completed 3,600 hours of qualifying practice generally needs both:
- a written practice agreement with a collaborating physician; and
- written practice protocols appropriate to the NP’s certified specialty and actual services.
The collaborating physician must be licensed in New York and qualified to collaborate in the specialty involved. The relationship supports consultation, referral, record review, and resolution of clinical disagreements. It does not make the physician the NP’s day-to-day supervisor.
Under the law in effect on September 7, 2026, an NP who has completed 3,600 qualifying hours is not required to comply with the statutory provisions concerning physician collaboration, written practice agreements, or written protocols. The provision allowing that exemption is currently scheduled to remain effective until July 1, 2030.
That date matters. New York extended the experienced-NP framework in 2026; it did not make the framework permanent. Clinics should therefore verify the law again before July 1, 2030, or whenever structuring an agreement intended to run beyond that date.
What Experience Counts Toward the 3,600-Hour Rule?
NYSED describes qualifying experience as practice as a licensed or certified NP:
- in accordance with the laws of New York or another state; or
- while employed by the U.S. Department of Veterans Affairs, the U.S. Armed Forces, or the U.S. Public Health Service.
The threshold is based on qualifying NP practice hours, not merely years since graduation, time holding a license, or hours worked in another clinical role. A clinic should document how the hours were earned before treating the NP as exempt.
NYSED’s public guidance uses the phrase “completed 3,600 hours,” while the statutory text refers to an NP “practicing for more than” 3,600 hours. Because eligibility determines whether the written-agreement requirement applies, an NP at or near the threshold should confirm their status with NYSED rather than estimate it.
What Must the Written Practice Agreement Include?
For an NP who remains below the experience threshold, the written practice agreement should address the actual practice—not simply repeat generic legal language. NYSED identifies the following elements:
- Referral and consultation. The agreement should explain when and how the NP will consult the physician or refer a patient.
- Emergency absence coverage. It should address coverage when either the NP or physician is unexpectedly unavailable.
- Resolution of disagreements. It must establish how the parties resolve disagreements about diagnosis or treatment within their overlapping scopes. If it does not, the physician’s determination prevails.
- Patient-record review. The physician must review records in a timely manner and at least once every three months.
- Identification of protocols. The agreement must identify the written practice protocols the NP will use.
- Other agreed provisions. The parties may add requirements appropriate to the specialty, services, setting, or risk profile.
The names of the NP and collaborating physician must also be clearly posted in the NP’s practice setting. A copy of the agreement must be retained at the NP’s practice location or locations and made available if NYSED requests it.
How many charts must the physician review?
New York does not prescribe a minimum number or percentage of charts. The parties should choose a defensible review sample based on the NP’s experience, the physician’s familiarity with the NP, patient complexity, practice volume, services offered, and clinical setting.
The agreement should state the cadence, selection method, documentation process, feedback method, and responsibility for preserving the review record. “Quarterly review required” without evidence that reviews occurred is weak compliance documentation.
Written Practice Protocol Requirements
The protocols are separate from the practice agreement. They must reflect:
- the specialty area in which the NP is certified;
- the services the NP actually provides; and
- current accepted medical and nursing practice.
Additional subspecialty protocols may be appropriate for services such as dermatology, orthopedics, or hematology. NYSED states that these additional protocols do not necessarily have to appear in the collaboration agreement itself.
As of September 7, 2026, New York law does not impose the future 90-day protocol-filing requirement. Current NYSED guidance instead requires the agreement to be kept at the practice setting and available for inspection. The statutory text presently schedules a protocol-filing requirement to take effect on July 1, 2030 if the Legislature does not change the law again.
Treating that future provision as a current 2026 filing deadline would be inaccurate.
The Four-NP Off-Site Limit
One physician may not enter written practice agreements with more than four NPs who are not located on the same physical premises as the physician.
Three details are important:
- The limit applies to written practice agreements, so it principally affects NPs who have not completed the experience threshold.
- It applies when the NP and physician are not on the same physical premises.
- The statute does not state the same numerical cap for NPs who practice on the physician’s premises.
A physician working with several practices should count every qualifying off-site agreement across all businesses before accepting another relationship. Each clinic should also verify the physician’s remaining capacity rather than relying only on the physician’s representation that they are “available in New York.”
Does the Physician Need Specialty Certification?
New York Education Law requires a licensed physician “qualified to collaborate in the specialty involved.” NYSED similarly says the physician must be qualified to practice in the NP’s specialty area.
That is not the same as a universal rule requiring board certification in the identical specialty. Qualification should be evaluated from the physician’s license status, education, training, clinical experience, current competence, and ability to provide meaningful consultation for the NP’s population and services.
For example, a high-acuity psychiatric practice should not choose a physician whose experience is unrelated to behavioral health simply because the physician holds an unrestricted New York license. The agreement file should contain enough information to show why the physician was considered qualified.
New York’s Fee-Splitting Rule
New York prohibits fee splitting and kickbacks between an NP and collaborating physician. The highest-risk structure is compensation based on a percentage of the NP’s fees, receipts, or professional income. Payments connected to patient referrals are also problematic.
NYSED states that an NP may pay a collaborating physician the fair market value of genuine personal services, such as consultation and chart review, provided that:
- the payment does not reward referrals;
- the NP is not required to refer patients to the physician; and
- the payment is not a percentage of, or otherwise dependent on, the NP’s professional fees or income.
A fixed monthly fee can reduce fee-splitting risk, but the label “flat fee” does not automatically make an arrangement compliant. The amount should represent fair market value for documented services. The agreement should define the work included, such as consultation availability, quarterly record review, protocol support, meetings, and additional-location coverage.
New York does not require the collaboration agreement itself to include a payment provision. The parties may address compensation in a separate services agreement, provided the full arrangement is legally compliant.
What Does a Collaborating Physician Cost in New York?
Current published pricing data does not support treating $799 per month as New York’s general market starting point. That figure is a particular vendor’s advertised starting price, not a statewide legal fee or neutral market average.
Two published 2026 benchmarks place standard New York compensation around the mid-$500s:
- one market analysis reports average New York physician pay of approximately $524 per month; and
- another contract-based dataset reports a $549 monthly median and a middle-market band of approximately $499 to $574.
A practical planning range for a standard agreement is therefore roughly $500 to $750 per month, while recognizing that actual quotes may fall outside it. Pricing can increase when the work includes:
- multiple NPs or locations;
- a specialty with a smaller pool of qualified physicians;
- more frequent or extensive chart review;
- complex patient populations or higher-acuity services;
- controlled-substance prescribing;
- protocol development or substantial compliance support;
- in-person availability or travel; or
- separate malpractice, onboarding, or platform costs.
Clinics should compare quotes on an all-in basis. Confirm whether the price includes the physician’s professional fee, malpractice coverage for the collaboration role, platform or matching fees, protocol work, added locations, and termination support. Our collaborating physician fees guide explains the major cost drivers.
Compensation is a market term, not a state-set rate. It should also be reviewed for fair-market-value and fee-splitting compliance.
Can the Collaboration Be Remote?
New York does not impose a universal rule requiring the collaborating physician to remain physically present at the NP’s practice. A properly structured relationship may therefore operate remotely.
Remote does not mean passive. For an NP below 3,600 hours, the physician must still be meaningfully available for consultation and referral, complete the required record reviews, support the agreement and protocols, and satisfy any duties added by the parties or the practice setting. The four-NP cap specifically addresses written agreements with NPs who are off-site from the physician.
Facilities, payers, employers, malpractice carriers, telehealth rules, and particular services may impose requirements beyond Education Law § 6902. Those requirements should be checked separately.
Common New York Compliance Mistakes
- Treating collaboration as supervision. New York holds the NP independently responsible for patient diagnosis and treatment.
- Using license age instead of documented practice hours. The formal exemption turns on qualifying NP practice experience.
- Applying the post-3,600 rule too early. The clinic should retain evidence supporting the NP’s experience calculation.
- Calling the physician “specialty certified” without support. The legal standard is whether the physician is qualified to collaborate in the specialty involved.
- Failing to document quarterly record review. The law does not set a chart count, but it does require timely review at least every three months.
- Exceeding the four-off-site-agreement limit. The count follows the physician across separate practices.
- Paying a percentage of revenue. A revenue-dependent collaboration fee may constitute prohibited fee splitting.
- Assuming any flat fee is safe. Compensation should reflect fair market value for genuine, documented services and remain independent of referrals and practice revenue.
- Applying the 2030 fallback rules in 2026. The attested-collaboration and 90-day protocol-filing provisions shown in the statute are scheduled for July 1, 2030, not currently in effect.
How to Put a Compliant New York Arrangement in Place
Before signing, confirm:
- the NP’s certified specialty and documented qualifying practice hours;
- whether a written agreement and protocols are currently required;
- the physician’s active New York license and qualifications for the specialty involved;
- the physician’s existing number of off-site written agreements;
- how consultation, referral, absence coverage, disputes, and quarterly review will work;
- where the agreement, protocols, and review records will be stored;
- that compensation reflects genuine services and is not tied to revenue or referrals; and
- whether facility, payer, malpractice, prescribing, telehealth, or business-ownership rules add further obligations.
Our detailed New York compliance guide examines the statutory provisions in greater depth. Clinics seeking a physician can also review our matching process.
Final Thoughts
New York’s framework is more nuanced than a simple yes-or-no collaboration rule. NPs below 3,600 qualifying hours generally need a written practice agreement and protocols. Experienced NPs are exempt from those requirements under the law in force through July 1, 2030. For agreements that are required, the most important operational rules are quarterly record review, physician qualification in the specialty, retention of the agreement at the practice setting, and the four-NP off-site cap.
The compensation structure deserves equal attention.New York permits fair-market-value payment for actual physician services, but revenue-dependent payments and referral compensation can cross into prohibited fee splitting.
Are you a physician interested in working with a New York NP-led practice? Apply to join Collaborating Physician. Applications take under ten minutes, and physicians pay no platform fee at any stage.
New York clinics and providers can request a physician match. Availability and timing depend on specialty, location, scope, and licensing requirements.
Frequently Asked Questions
Do all New York NPs need a collaborating physician?
No. An NP who has not completed 3,600 hours of qualifying practice generally needs a written practice agreement and written protocols with a qualified physician. Under the law in effect through July 1, 2030, an NP who has completed the threshold is exempt from those formal collaboration requirements.
Does a New York NP become fully independent after 3,600 hours?
The NP is exempt from the physician-collaboration, written-agreement, and written-protocol provisions of Education Law § 6902(3)(a) under the current temporary framework. The NP must still practice within their New York certification, professional scope, and all other applicable facility, prescribing, payer, telehealth, and business rules.
What must a New York written practice agreement include?
It should address referral and consultation, coverage for emergency absences, resolution of diagnostic or treatment disagreements, patient-record review at least every three months, and identification of the written protocols the NP will use.
How many NPs can one physician collaborate with in New York?
One physician may not enter written practice agreements with more than four NPs who are not located on the same physical premises as the physician. The statute does not state the same cap for co-located NPs or experienced NPs who are exempt from written agreements.
Must New York practice protocols be filed within 90 days in 2026?
No. The statute currently schedules the 90-day filing provision to take effect on July 1, 2030. In 2026, the agreement must instead be kept at the NP’s practice setting or settings and made available for NYSED inspection.
Can a New York collaborating physician be paid a percentage of revenue?
Generally no. NYSED warns that a payment calculated as a percentage of, or otherwise dependent on, the NP’s professional fees or income may be illegal fee splitting. Payment should reflect fair market value for genuine physician services and must not reward or require referrals.
How much does a collaborating physician cost in New York?
Published 2026 benchmarks place ordinary New York arrangements around the mid-$500s per month, with a practical standard range of approximately $500 to $750. Specialty, workload, number of NPs, services, malpractice coverage, and platform fees can materially change the total.
Does the collaborating physician have to be on-site?
New York does not impose a universal continuous on-site requirement. Remote collaboration can be possible, but the physician must fulfill the agreement’s consultation, referral, record-review, and other obligations. Off-site written agreements also count toward the four-NP limit.
Primary Sources and Data Notes
- New York State Education Department: NP Practice Requirements
- New York Education Law § 6902
- NYSED Article 139 statutory text
- Single Aim New York compensation analysis, updated June 2026
Pricing figures are market benchmarks, not guaranteed quotes or state-set fees.
Disclaimer: This article is for educational and informational purposes only and does not constitute legal, medical, tax, or financial advice. Laws and agency guidance change. Verify current requirements with NYSED and have qualified New York healthcare counsel review the facts and contracts for a specific practice.
