Georgia collaborating physician requirements are among the most detailed and actively enforced in the country. Georgia is a restricted-practice authority state for nurse practitioners, meaning APRNs must operate under a written nurse protocol agreement with a delegating physician for the full duration of their career. There is no pathway to independent APRN practice in Georgia regardless of experience, specialty, or years in the field.
For physicians considering a collaboration role in this state, the compliance obligations go well beyond signing a document. Georgia requires board filing, geographic proximity between the physician and the practice, annual onsite observation, quarterly chart review, and specific oversight of every patient receiving controlled substances. Getting each of these requirements right before and after the agreement is signed is what separates a defensible Georgia collaboration from a regulatory liability.
This guide covers every requirement a physician needs to understand in 2026, sourced directly from Georgia statutes and board rules.
Georgia Collaborating Physician Overview: Where Georgia Stands
Georgia classifies APRNs in the restricted-practice category with no expiration. Physician oversight is a career-long legal requirement. The collaborating physician in Georgia is called the delegating physician, and the relationship is formalized through a nurse protocol agreement rather than a prescriptive authority agreement or collaborative practice agreement.
Governing Bodies
Two regulatory bodies govern these arrangements:
- Georgia Composite Medical Board (GCMB): Governs physician licensure, receives and reviews nurse protocol agreements filed under OCGA 43-34-25, and enforces compliance with delegation rules. The GCMB can request the nurse protocol agreement at any time and take disciplinary action against the delegating physician for noncompliance.
- Georgia Board of Nursing: Governs APRN licensure and maintains oversight of APRN scope of practice under OCGA 43-26-5.
Both boards can act independently when reviewing compliance failures. A complaint against an APRN can trigger scrutiny of the delegating physician’s documentation, and vice versa.
The Two Protocol Frameworks: OCGA 43-34-23 vs. OCGA 43-34-25
Georgia is one of the few states that distinguishes between two separate legal pathways for APRN practice, and understanding which one applies to a given arrangement determines the physician’s specific obligations.
OCGA 43-34-23: Without Prescriptive Authority
Under this statute, the APRN provides clinical care but does not sign prescriptions in their own name. Instead, the APRN calls in prescriptions under the collaborating physician’s name to the pharmacy. A protocol agreement is signed under this framework and kept on-site at the practice location. It is not submitted to the Georgia Composite Medical Board. No board filing fee is required.
OCGA 43-34-25: With Prescriptive Authority
Under this statute, the APRN signs prescriptions in their own name. This is the framework used by most NP-operated clinics in Georgia. The nurse protocol agreement under OCGA 43-34-25 must be submitted to the Georgia Composite Medical Board within 30 days of execution. The APRN does not have prescriptive authority until the Board has reviewed and approved the agreement. Filing fees apply.
Most clinics seeking a collaborating physician in Georgia are operating or intending to operate under OCGA 43-34-25. This guide focuses on the requirements under that framework unless otherwise noted.
The Nurse Protocol Agreement: Georgia’s Core Compliance Document
The nurse protocol agreement is the written delegation instrument through which the delegating physician authorizes the APRN to perform specific medical acts, including prescribing. It is not a general collaboration document. Georgia treats it as a delegation of authority, and the specific acts delegated must be described with enough precision that any regulator reviewing the agreement can determine exactly what the APRN is and is not authorized to do.
Under OCGA 43-34-25 and Ga. Comp. R. & Regs. R. 360-32-.02, the nurse protocol agreement must be reviewed, revised, and updated annually by the delegating physician and the APRN. The annual review is mandatory. Each revision must be re-executed, and any amendments must be filed with the Georgia Composite Medical Board within 30 days of execution.
What Must Be in a Georgia Nurse Protocol Agreement
Georgia law and board rules specify the minimum required content under Ga. Comp. R. & Regs. R. 360-32-.02. The agreement must contain all of the following:
1. Party Identification
Names, addresses, telephone numbers, license numbers, and DEA numbers (where applicable) for all parties, including any designated physician listed for backup consultation.
2. Practice Description
A description of the practice and all practice locations, including both the primary and any satellite sites, along with the APRN’s specialty area and field of certification.
3. Delegated Medical Acts
The specific medical acts delegated to the APRN, including drugs and devices the APRN may prescribe, treatments the APRN may order, and diagnostic studies the APRN may initiate. The scope of delegated acts must be consistent with the APRN’s education, training, certification, and the delegating physician’s comparable specialty.
4. Immediate Consultation Provisions
The agreement must provide for immediate consultation with the delegating physician or a designated physician. If the delegating physician is not available at any time when the APRN is practicing under the agreement, the agreement must identify another physician who concurs with its terms and is available to fill that role. If no designated physician is named and the delegating physician is unavailable, the APRN cannot practice.
5. Medical Record Review Schedule
A schedule for the physician’s periodic review of patient records. The minimum review standards are defined in Ga. Comp. R. & Regs. R. 360-32-.02 and are addressed separately in the oversight obligations section of this guide.
6. Controlled Substance Prescribing Parameters
Written procedures for ordering controlled substances, where applicable. The agreement must define which controlled substances are authorized. Georgia restricts what APRNs can prescribe in this category, and those restrictions must be reflected in the agreement.
7. Imaging Orders
If the APRN is authorized to order imaging studies (CT, MRI, PET, nuclear medicine), the agreement must specify that all such tests shall be read and interpreted by a physician trained in that specialty, and that a copy of the report shall be forwarded to the delegating physician.
8. Emergency Plan
A predetermined plan for emergency services and patient conditions that require direct, on-site physician evaluation or consultation.
9. Professional Samples Authorization
A statement indicating whether the APRN is authorized to request, receive, sign for, and distribute professional drug samples.
10. Review Dates
A current review date and dates of all amendments. The agreement must be updated annually, and each amendment must be dated and filed with the Board within 30 days.
Board Filing: Submission, Approval, and Timeline
The nurse protocol agreement under OCGA 43-34-25 must be submitted to the Georgia Composite Medical Board within 30 days of being signed by both parties. As of July 2025, all submissions must be completed through the GCMB’s ThoughtSpan Licensing Gateway. Paper submissions are no longer accepted.
The Approval Requirement
The APRN does not have prescriptive authority until the Board reviews and approves the agreement. Signing the agreement does not activate prescribing rights. The APRN may begin seeing patients and signing prescriptions only after the Board has completed its review. The GCMB’s current processing time averages approximately 30 business days, though complex agreements may take longer. Both parties should plan their practice launch timeline around the approval window.
Amendment Filing
Any amendments to an active nurse protocol agreement must be filed with the Georgia Composite Medical Board within 30 days of execution. Amendments that are executed but not filed leave the registered agreement out of step with actual practice, which creates a compliance gap.
Board Authority to Require Changes
The GCMB may require changes to a nurse protocol agreement if it determines the agreement does not comply with OCGA 43-34-25 or accepted standards of medical practice. Failure to provide documents requested by the Board within 30 days is a basis for disciplinary action against the delegating physician.
Geographic Proximity Requirements: The 50-Mile Rule
Georgia imposes a geographic proximity requirement on delegating physicians that is not present in most other states. Under OCGA 43-34-25(a)(12), a delegating physician must either:
- Have a principal place of practice within Georgia, or
- Have a principal place of practice outside Georgia but within 50 miles of the location where the nurse protocol agreement is being utilized
This requirement applies to both the delegating physician and any designated physician listed in the agreement. Virtual addresses, P.O. Boxes, and hourly or daily flex rental spaces are not acceptable as a principal place of practice for this purpose. The physician’s principal place of practice is defined as the location from which the physician treats patients more than 50% of the time.
The 50-mile rule has direct implications for remote collaboration in Georgia. A physician whose primary practice is in another state can serve as a delegating physician for a Georgia clinic, but only if that primary practice is within 50 miles of the Georgia clinic location. A physician in Tennessee practicing near Chattanooga can potentially collaborate with an APRN in northern Georgia. A physician in Texas cannot.
Physician Eligibility and the Specialty Comparability Standard
A Georgia delegating physician must hold an active medical license issued by the Georgia Composite Medical Board. The physician’s license must be in good standing and the physician must be actively practicing medicine.
The Comparable Specialty Requirement
Georgia is one of a small number of states that enforces a formal specialty comparability standard. Under Georgia law and GCMB guidance, a delegating physician and APRN must have comparable specialties in order to enter into a nurse protocol agreement together.
There are two ways a specialty practice physician can delegate prescriptive authority to an APRN when specialty comparability is in question:
- The nurse protocol agreement can specify that the APRN will perform only primary care functions while undergoing specialty training, with documentation of that training submitted to the Board upon completion.
- Documentation can be submitted showing that the APRN has qualifications, training, and experience that make their specialty comparable to that of the delegating physician.
This requirement has real consequences for the most common Georgia clinic types. A primary care physician can generally collaborate with an APRN providing primary care, weight loss, or IV hydration services. Delegating prescriptive authority over psychiatric medications, dermatological procedures, or specialty-specific clinical protocols requires meaningful specialty overlap and documented justification when the match is not straightforward.
Employment Restrictions
Georgia generally prohibits a physician from being employed by an APRN they supervise. A delegating physician should not enter into an arrangement where the APRN is both their supervisor and the beneficiary of the physician’s delegation.
Ongoing Oversight Obligations: Chart Reviews and Onsite Observation
Georgia has some of the most specific ongoing oversight requirements of any state in the country. These obligations are not aspirational. They are defined in Ga. Comp. R. & Regs. R. 360-32-.02 and R. 360-32-.05 and apply to every active nurse protocol agreement.
Annual Onsite Observation
The delegating physician must conduct direct onsite observation of the APRN’s practice at least once annually. This requirement exists outside of the quarterly medical records review obligation. Physicians who never visit the practice location are not meeting this standard.
Quarterly Medical Records Review
The delegating physician must conduct a review of medical records on at least a quarterly basis. This review may be conducted via telecommunications. The minimum review standards by patient category are:
| Patient Category | Review Requirement |
| Patients receiving controlled substance prescriptions | 100% of records reviewed and signed; at least quarterly |
| Patients with adverse outcomes | 100% of records reviewed and signed within 30 days of discovery |
| All other patient records | At minimum 10% reviewed; at least annually |
These are not suggested minimums. They are the regulatory floor. A delegating physician who reviews fewer than 100% of controlled substance patient records is not in compliance with Georgia law regardless of the volume of patients involved.
Quarterly Collaboration Meetings
The delegating physician and APRN must participate in and document quarterly clinical collaboration meetings. These may be conducted by telephone, in person, or onsite. The purpose of the meetings is to monitor the care being provided to patients. The meetings must be documented.
Patient Notification
The delegating physician’s name, contact information, and record of each visit must be provided to the patient’s primary care provider of choice, with the patient’s consent, within 24 hours of the visit.
The Physician-to-APRN Ratio in Georgia
Georgia imposes a hard cap on the number of APRNs a single physician may collaborate with at one time. The general rule under OCGA 43-34-25 is:
- A delegating physician may enter into nurse protocol agreements with no more than four APRNs at any one time.
The Accredited Facility Exception
Under OCGA 43-34-25(g.1), a physician practicing at a location that maintains evidence-based clinical practice guidelines and is accredited by an accrediting body approved by the Board (such as The Joint Commission) may enter into nurse protocol agreements with up to a combined equivalent of eight APRNs and PAs at one time.
For physicians collaborating exclusively with APRNs in non-accredited settings, the cap is four. This is a strict limit, not a guideline. A physician who enters into a fifth agreement while four are active is operating outside compliance from the moment the fifth agreement is signed.
Controlled Substance Prescribing in Georgia
Georgia places significant restrictions on APRN prescribing of controlled substances. These restrictions are among the most restrictive of any state in the country and must be accurately reflected in every nurse protocol agreement.
Schedule I and II: Prohibited
APRNs in Georgia may not prescribe Schedule I or Schedule II controlled substances under any nurse protocol agreement. This prohibition is absolute. It applies regardless of the delegating physician’s specialty, the clinic type, or any other factor.
This restriction has direct implications for clinic types that commonly involve Schedule II prescribing, including psychiatric practices that prescribe stimulants for ADHD, pain management clinics, and any setting where Schedule II medications are part of the standard treatment plan. For those clinic types in Georgia, Schedule II prescriptions must come from the physician directly, not from the APRN.
Schedules III through V
APRNs may be authorized to prescribe Schedule III through V controlled substances under a nurse protocol agreement, subject to the oversight requirements described above. Every patient receiving a controlled substance prescription under the protocol must be evaluated or examined by the delegating physician or a designated physician at least quarterly.
DEA Registration
An APRN prescribing controlled substances under OCGA 43-34-25 must hold their own DEA number. They may not use the delegating physician’s DEA number for controlled substance prescriptions when practicing under this framework.
Termination Obligations
Georgia places specific notification obligations on both parties when a nurse protocol agreement ends.
- The delegating physician must notify the Georgia Composite Medical Board within 10 working days of the date of termination of a nurse protocol agreement.
- If the delegating physician dies or departs unexpectedly, the APRN must notify the Board within 7 days.
- When the delegating physician leaves a practice, the protocol agreement terminates. The agreement does not transfer to another physician.
- Either party may terminate without cause by giving the other party at least 30 days advance written notice.
These timelines are firm. A physician who fails to notify the Board within 10 working days of terminating an agreement is not in compliance from the day the deadline passes.
Common Compliance Mistakes Georgia Collaborating Physicians Make
Georgia’s compliance requirements are specific enough that documentation failures are common even among physicians who understand their general obligations.
- Agreement not filed within 30 days. The nurse protocol agreement must be submitted to the GCMB within 30 days of execution. Physicians who sign the agreement and assume the APRN is handling the filing without confirming submission miss this deadline regularly.
- APRN begins prescribing before Board approval. The APRN does not have prescriptive authority until the Board reviews and approves the agreement. Prescribing that begins immediately after signing, before approval arrives, is operating outside the legal framework.
- No onsite observation conducted. The annual onsite visit is a mandatory documented obligation. Physicians who provide remote oversight without ever visiting the practice location are not meeting the requirement.
- 100% controlled substance chart review not completed. Reviewing a sample of controlled substance patient records does not satisfy the Georgia requirement. Every patient who receives a controlled substance prescription under the protocol must have their record reviewed and signed by the delegating physician at least quarterly.
- Four-APRN cap exceeded. Physicians collaborating with multiple clinics need to count all active agreements toward the four-APRN limit. Entering a fifth arrangement without qualifying for the accredited facility exception creates an immediate compliance violation.
- Amendment not filed within 30 days. Changes to an active protocol agreement must be filed with the GCMB within 30 days of execution. Amended agreements that are never filed leave the official record out of step with actual practice.
- Termination not reported within 10 days. When a collaboration ends, the delegating physician must notify the GCMB within 10 working days. Missed termination filings leave both the physician and the APRN in a legally ambiguous position.
Georgia Collaborating Physician Requirements: Quick Reference
Physician Eligibility
- Active Georgia MD or DO license in good standing
- Principal place of practice within Georgia or within 50 miles of the clinic location
- Specialty must be comparable to the APRN’s specialty
- Generally may not be employed by the APRN they supervise
Core Compliance Document
- Written nurse protocol agreement meeting all requirements of OCGA 43-34-25 and Ga. Comp. R. & Regs. R. 360-32-.02
- Must identify parties, practice locations, delegated medical acts, consultation procedures, controlled substance parameters, imaging protocols, emergency plan, and review dates
Board Filing
- Agreement submitted to GCMB within 30 days of execution via ThoughtSpan Licensing Gateway
- APRN has no prescriptive authority until Board approval
- Amendments filed with GCMB within 30 days of execution
- Delegating physician notifies Board within 10 working days of termination
Review Cycle
- Agreement reviewed and updated annually
- Each annual revision must be re-executed and filed
Ongoing Oversight Obligations
- Annual direct onsite observation of the APRN’s practice
- Quarterly chart review (10% of standard records; 100% of controlled substance records)
- Quarterly clinical collaboration meetings, documented
- Adverse outcome records reviewed within 30 days of discovery
Physician-to-APRN Ratio
- Maximum of 4 APRNs at one time in standard settings
- Maximum of 8 combined APRNs/PAs at accredited facilities with evidence-based practice guidelines
Geographic Requirement
- Delegating physician’s principal place of practice must be in Georgia or within 50 miles of the clinic location
Controlled Substance Limits
- Schedule I and II: prohibited for APRNs
- Schedule III through V: permitted under the nurse protocol agreement with quarterly patient evaluation by the physician
Final Thoughts
Georgia collaborating physician requirements are among the most detailed in the country, and they are actively enforced. The nurse protocol agreement is not a background document filed and forgotten. It is the legal instrument governing every medical act the APRN performs under the delegation, and it must be current, specific, and backed by documented onsite observation and quarterly oversight activity.
For physicians entering the Georgia market, the compliance framework demands consistent attention across the full duration of the collaboration. Annual agreement reviews, quarterly chart reviews, quarterly collaboration meetings, onsite observation, and timely board filings are not optional components of the arrangement. They are the arrangement.
Build a Compliant Georgia Collaboration With Collaborating Physician
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The platform connects licensed physicians with vetted APRN-operated clinics across Georgia and 50-plus other states. Every arrangement is built with state-specific compliance in mind, including Georgia’s nurse protocol requirements, GCMB filing obligations, the 50-mile proximity rule, quarterly oversight standards, and the four-APRN ratio cap. 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.
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Disclaimer: This content is for educational and informational purposes only. It does not constitute legal or medical advice. Georgia healthcare regulations change frequently. Always verify current requirements directly with the Georgia Composite Medical Board, the Georgia Board of Nursing, and a qualified healthcare attorney before making any practice decisions.
Frequently Asked Questions
Does a Georgia collaborating physician need to be physically present at the APRN’s clinic?
The delegating physician must be immediately available for consultation at all times when the APRN is practicing under the agreement, in person or by electronic means. Beyond availability, the physician must conduct direct onsite observation of the APRN’s practice at least once annually. The quarterly medical records review may be conducted via telecommunications. Regular physical presence beyond the annual onsite observation is not mandated by rule, but the physician must never be genuinely unreachable when the APRN is practicing.
How many APRNs can one Georgia physician collaborate with?
In standard settings, a delegating physician may enter into nurse protocol agreements with no more than four APRNs at one time. At locations accredited by an approved accrediting body such as The Joint Commission that maintain evidence-based clinical practice guidelines, the combined cap for APRNs and PAs rises to eight. Physicians collaborating across multiple clinics must count all active agreements toward whichever limit applies.
Does Georgia allow APRNs to prescribe Schedule II controlled substances?
No. Georgia APRNs may not prescribe Schedule I or Schedule II controlled substances under any nurse protocol agreement. This prohibition is absolute and applies regardless of the physician’s specialty or the type of clinic. APRNs in Georgia may be authorized to prescribe Schedule III through V controlled substances under a properly filed nurse protocol agreement.
When does a Georgia nurse protocol agreement need to be filed with the Board?
The agreement must be submitted to the Georgia Composite Medical Board within 30 days of being signed by both parties. Any amendments must also be filed within 30 days of execution. As of July 2025, all submissions must be completed through the GCMB’s ThoughtSpan Licensing Gateway. The APRN does not have prescriptive authority until the Board reviews and approves the agreement.
What happens when a Georgia nurse protocol agreement terminates?
The delegating physician must notify the GCMB within 10 working days of the date of termination. If the physician dies or departs unexpectedly, the APRN must notify the Board within 7 days. When the delegating physician leaves a practice, the protocol agreement terminates. It does not transfer to another physician. Either party may terminate without cause by providing at least 30 days advance written notice to the other party.
Does the Georgia collaborating physician need to be a specialist?
Georgia requires that the delegating physician and APRN have comparable specialties. This requirement applies to the scope of acts delegated in the nurse protocol agreement. A general or primary care physician can typically collaborate with an APRN providing primary care, weight loss, or similar non-specialty services. For specialty-specific delegation, the physician’s specialty must be comparable to the APRN’s, or documentation must be submitted showing that the APRN has qualifying training and experience in that specialty area.
