Indiana collaborating physician requirements apply to a restricted-practice state where every APRN seeking prescriptive authority must operate under a written collaborative practice agreement with a licensed practitioner. Indiana Code § 25-23-1-19.4 requires that collaborative practice agreements be in place before an APRN can provide services requiring physician collaboration, and the agreement must be submitted to and approved by the Indiana State Board of Nursing before the APRN may write a single prescription.
For physicians entering collaboration roles in Indiana, the compliance framework includes a board submission and approval requirement, a geographic proximity standard, a weekly chart review obligation tied to specific documentation timelines, a biennial audit program conducted by the Indiana Professional Licensing Agency, and specific controlled substance registration requirements. This guide covers every requirement a physician needs to understand in 2026, sourced directly from Indiana statutes and administrative rules.
Indiana Collaborating Physician Overview: Where Indiana Stands
Indiana classifies APRNs in the restricted-practice category. The collaborative practice agreement is required for all APRNs seeking prescriptive authority, and that requirement has been the consistent framework in Indiana despite repeated legislative attempts to move toward full practice authority.
Governing Bodies
Two regulatory bodies govern APRN-physician collaboration in Indiana:
- Indiana State Board of Nursing (ISBN): Governs APRN licensure, prescriptive authority applications, collaborative practice agreement review and approval, and disciplinary oversight of APRNs under IC § 25-23-1 and 848 IAC 5.
- Indiana Medical Licensing Board (IMLB): Governs physician licensure, accepts and reviews complaints concerning physician collaborative practice agreements with APRNs, and enforces compliance with physician obligations in collaborative arrangements.
Under Indiana Code, the Indiana Medical Licensing Board is specifically required to accept and review complaints concerning physician collaborative practice agreements with APRNs, giving the board a direct oversight role in how physicians discharge their collaboration obligations.
The 2025 to 2026 Legislative Context
Multiple bills have been introduced in the 2025 to 2026 Indiana legislative session that propose to remove the collaborative practice agreement requirement entirely. House Bill 1116 and Senate Bill 383 were both introduced in early 2025 proposing to eliminate the CPA requirement effective July 1, 2025. House Bill 1129, introduced in the same session, includes the same elimination with an effective date of July 1, 2026 and also proposes allowing APRNs with prescriptive authority to prescribe Schedule II controlled substances for weight reduction or obesity control, which was previously prohibited.
As of the publication date of this guide, these bills have not been enacted and the CPA requirement under IC § 25-23-1-19.4 remains in full force. Physicians entering Indiana collaboration arrangements should monitor these bills closely given the active legislative movement in this state.
The Collaborative Practice Agreement: Indiana’s Core Compliance Document
Indiana requires a written collaborative practice agreement formalized between the APRN and a licensed practitioner. The agreement must be signed by both parties and must be submitted to the Indiana State Board of Nursing as part of the APRN’s prescriptive authority application. Written practice agreements for NPs applying for prescriptive authority shall not be valid until prescriptive authority is granted by the Indiana State Board of Nursing.
The Agreement Is Not Valid Until Board Approval
This is one of the most operationally critical aspects of Indiana’s framework. Unlike states where the agreement takes effect upon signing, in Indiana the agreement has no legal effect for prescriptive authority purposes until the ISBN issues approval. An APRN who begins prescribing after signing the CPA but before receiving the ISBN approval letter is operating outside the legal framework from the first prescription.
Physicians should confirm that the ISBN approval has been received before the APRN begins any prescribing activity under the arrangement.
Change and Termination Notification
APRNs must immediately notify the Indiana State Board of Nursing in writing of any changes in or termination of the written practice agreement, including any changes in the prescriptive authority of the physician. Immediate notification is required, not notification within a defined window. Physicians who reduce or lose their prescriptive authority while a collaboration is active must ensure the APRN is notified and that the ISBN is informed of the change.
What Must Be in an Indiana CPA
Indiana Administrative Code 848 IAC 5-1-1 specifies the required content of a valid collaborative practice agreement. The agreement must address all of the following:
1. Identification of the Parties
The agreement must include a list of all other written collaborative practice agreements to which the licensed practitioner is a party, including the names of any other APRNs with whom the physician has current agreements and any other licensed practitioners with whom the APRN has current agreements. This disclosure structure ensures both parties and the board have a full picture of the collaboration landscape.
2. Description of Collaboration Methods
The agreement must describe how collaboration will occur, including the methods by which the physician will be available for consultation and the process for addressing clinical questions and emergencies that arise during the APRN’s practice.
3. Geographic Proximity
The practice agreement must address geographic proximity between the APRN and the collaborating physician. Indiana requires geographic proximity as a condition of the collaboration but does not define a specific mileage limit. The agreement must reflect that proximity is maintained in a manner consistent with the oversight obligations the physician assumes.
4. Coverage During Absences
The agreement must address how the health care needs of patients will be covered during any absence of the physician. A plan for emergency and planned absence coverage must be described and documented in the agreement.
5. Limitations on Prescriptive Authority
The agreement must describe any limitations the physician places on the APRN’s prescriptive authority. This includes any drug categories, schedules, or patient populations for which the APRN’s prescribing is restricted. Limitations must be explicit. Silence on a restriction is not equivalent to an absence of limitations.
6. Physician Review of Prescribing Practices
The agreement must establish a process for the physician’s ongoing review of the APRN’s prescribing. Under 848 IAC 5-1-1(a)(7)(D), the physician must review at least a 5% random sampling of charts and prescribed medications submitted by the APRN. The APRN must submit that documentation to the physician on a weekly basis, and the physician must complete the review within seven days of receipt.
Board Submission: How the Filing Process Works
Indiana’s board submission process is a prerequisite for prescriptive authority, not a post-practice administrative step.
How to Submit
The APRN submits the collaborative practice agreement to the Indiana State Board of Nursing with the prescriptive authority application, using a mandatory Cover Sheet. The submission must include original signatures from both the APRN and the collaborating physician.
The Cover Sheet Requirement
The Indiana Professional Licensing Agency provides a specific Cover Sheet that must accompany every CPA submission. The Cover Sheet captures the identifying information for both parties and confirms the nature of the arrangement. Submissions without the Cover Sheet are not complete and will not proceed to review.
What Happens After Submission
The ISBN reviews the application and the agreement. Prescriptive authority is not effective until the Board issues a written approval. Both the physician and the APRN should retain the approval letter. The APRN cannot prescribe until this approval is in hand.
PA Collaboration Agreements
Physician assistants in Indiana must also submit their collaborative agreements to a board for approval. PAs email their agreements to the Indiana Professional Licensing Agency at pla5@pla.in.gov. If a PA is changing or adding a new collaborating physician other than the physician initially listed on their license, they must submit a Change and Addition of Collaborating Physician Application.
Physician Eligibility: License, Geographic Proximity, and Ratio
A qualifying Indiana collaborating physician must hold an active, unrestricted medical license issued by the Indiana Medical Licensing Board under IC § 25-22.5-5-2 and be in good standing. The physician cannot have disciplinary actions that impair their ability to supervise.
Geographic Proximity
Indiana requires geographic proximity between the APRN and the collaborating physician. The requirement is statutory but the specific distance is not numerically defined in state code or rule. The practice agreement must reflect that proximity is maintained in a manner appropriate to the scope of the arrangement and the physician’s ability to fulfill their oversight obligations.
In practice, the geographic proximity requirement means remote collaboration across large distances requires careful attention to whether the physician can genuinely fulfill the consultation, review, and availability obligations the arrangement creates.
The Physician Ratio
Under Indiana Administrative Code 848 IAC 5-1-1, a physician cannot collaborate with more than four APRNs or PAs simultaneously. Unlike some states that allow a higher number with certain exceptions, Indiana’s cap is a straightforward maximum of four concurrent collaborative arrangements at any one time.
This cap applies across all active arrangements regardless of the type of provider. A physician with two APRN agreements and two PA agreements has reached the maximum of four and cannot enter into a fifth arrangement without first ending one of the existing ones.
The Weekly Chart Review Requirement
Indiana’s chart review obligation is one of the most frequent ongoing tasks required of any collaborating physician in the country. Under 848 IAC 5-1-1, the physician must review the APRN’s prescribing practices on a weekly basis.
What the Review Must Cover
Each weekly submission must include at least a 5% random sampling of the charts and medications prescribed by the APRN during that period. The sampling must be random, not curated by the APRN to show favorable cases. The physician must complete the review of submitted documentation within seven days of receipt.
Documentation Requirements
The chart review process must be documented. Records of each weekly submission, the date received, and the date reviewed must be maintained. A review that occurred but was not documented does not provide a defensible compliance record if the IMLB or ISBN requests evidence of ongoing oversight.
Why This Standard Is Strict
Indiana’s weekly review cycle is among the most demanding of any state in the country. Physicians considering multiple Indiana collaboration arrangements must honestly assess whether they have the capacity to conduct weekly chart reviews for each active arrangement before entering into agreements. The obligation does not pause during vacations, conferences, or other absences. Coverage must be planned and documented.
The Biennial Audit Program
Indiana has an active state audit program for collaborative practice agreements that physicians should understand before entering any arrangement.
How the Audit Works
Under Indiana law, before December 31 of each even-numbered year, the Indiana Professional Licensing Agency will randomly audit at least 1% and not more than 10% of active practice agreements to verify compliance with Board requirements. The audit reviews the agreement documentation, the chart review records, the prescriptive authority approval, and related compliance materials.
What Physicians Must Maintain
Physicians in active Indiana collaborations must maintain organized, complete records that include the current board-approved CPA, the Cover Sheet and approval letter from the ISBN, weekly chart review documentation showing dates submitted, dates reviewed, and the materials reviewed, and records of any changes to the agreement including change notifications filed with the ISBN.
An audit that reveals missing documentation creates regulatory exposure for both the physician and the APRN. The audit program provides a regular compliance checkpoint that makes documentation habits from day one of the arrangement essential.
Prescriptive Authority and Controlled Substances in Indiana
Indiana APRNs with an approved collaborative practice agreement and a prescriptive authority certificate may prescribe Schedule II through V controlled substances within the terms of the agreement.
Controlled Substance Registration
For APRNs who will prescribe controlled substances, two additional registrations are required beyond the ISBN prescriptive authority approval:
- An Indiana Controlled Substances Registration (CSR) issued by the Indiana Professional Licensing Agency
- A federal DEA registration
Both must be active before any controlled substance prescription may be written. The CSR application may be submitted together with the prescriptive authority application in a single submission with a combined fee.
Schedule II Considerations
Indiana law currently prohibits APRNs from prescribing Schedule II controlled substances for weight reduction or to control obesity. This is one of the specific Schedule II limitations in the current framework. House Bill 1129 proposed removing this restriction, but as of the publication date of this guide, that change has not been enacted.
The practice agreement must describe the scope of controlled substance prescribing authorized, including any limitations the physician imposes on Schedule II prescribing. Physicians who do not want to authorize Schedule II prescribing in a particular arrangement must state that limitation explicitly in the agreement.
Pharmacology CE for APRNs
APRNs with prescriptive authority in Indiana are required to complete at least 30 hours of continuing education every two years, with 8 of those hours specifically focused on pharmacology. This is an APRN obligation, not a physician obligation, but physicians should be aware of it as context for the APRN’s ongoing qualifications.
The 2025 to 2026 Legislative Context: Full Practice Authority Bills
Indiana has been the site of active full practice authority legislation across multiple sessions. In the 2025 to 2026 session:
- HB 1116: Introduced January 8, 2025, proposed removing the CPA requirement effective July 1, 2025
- SB 383: Introduced in the same session with similar provisions
- HB 1129: Introduced with the same CPA removal plus the addition of Schedule II obesity prescribing authority, effective July 1, 2026
None of these bills had been enacted as of the publication date of this guide. The CPA requirement under IC § 25-23-1-19.4 remains in effect. However, the consistent legislative pressure toward full practice authority in Indiana indicates a market that may change materially in the coming sessions. Physicians entering long-term Indiana collaboration arrangements should plan around the possibility of the CPA requirement being eliminated.
Common Compliance Mistakes Indiana Collaborating Physicians Make
Most Indiana CPA compliance problems involve the approval process, the weekly chart review cadence, and ratio management.
- APRN begins prescribing before ISBN approval. The board must approve the CPA before prescriptive authority is effective. Physicians who sign the agreement and assume the APRN can begin prescribing immediately are creating a compliance gap. Approval confirmation from the ISBN must be received first.
- Weekly chart review not maintained. Indiana requires weekly submission and review of at least a 5% random sampling of charts. Physicians who fall behind on the weekly cycle or who skip reviews during absences are not meeting the standard, regardless of the volume of charts involved.
- Ratio exceeded. The cap of four concurrent APRN and PA arrangements is firm. Physicians who lose track of their active agreements across multiple clinics can inadvertently exceed this limit.
- Immediate notification not given on changes. The ISBN must be notified immediately of any changes in or termination of the practice agreement. Physicians who reduce their controlled substance prescribing authority or face license restrictions must notify the APRN immediately.
- Geographic proximity not genuinely maintained. The practice agreement must reflect geographic proximity between the physician and the APRN. Remote arrangements that leave the physician too distant to genuinely fulfill consultation obligations may not satisfy the requirement.
- Biennial audit documentation not ready. The IPLA audits between 1% and 10% of active agreements before December 31 of each even year. Physicians without organized compliance documentation are exposed when selected for audit.
Indiana Collaborating Physician Requirements: Quick Reference
Physician Eligibility
- Active, unrestricted Indiana MD, DO, or other licensed practitioner license under IC § 25-22.5-5-2
- In good standing with no disciplinary actions impairing supervision
- Geographic proximity to the APRN required (not numerically defined)
- Maximum of 4 concurrent APRN and PA arrangements simultaneously
Core Compliance Document
- Written collaborative practice agreement under IC § 25-23-1-19.4 and 848 IAC 5-1-1
- Must include: party identification with disclosure of all other active agreements, collaboration methods, geographic proximity, absence coverage, prescriptive authority limitations, weekly chart review process
- Submitted to ISBN with Cover Sheet as part of APRN prescriptive authority application
- Not valid until ISBN issues prescriptive authority approval
Board Submission
- Agreement submitted by APRN to ISBN with mandatory Cover Sheet and original signatures
- Prescriptive authority not effective until ISBN approval letter received
- Immediate notification of any changes or termination required to ISBN
Chart Review
- Physician reviews at least 5% random sampling of APRN charts weekly
- APRN submits documentation to physician within 7 days
- Physician completes review within 7 days of receipt
- All reviews documented and maintained
Biennial Audit
- IPLA audits 1% to 10% of active agreements before December 31 of even-numbered years
- Both physician and APRN compliance documentation must be ready for audit
Controlled Substances
- Schedule II through V authorized within the agreement
- Indiana CSR and DEA registration required for controlled substance prescribing
- Schedule II obesity/weight reduction prescribing currently prohibited pending HB 1129
Geographic Requirement
- Geographic proximity required; specific mileage not defined
Physician-to-APRN Ratio
- Maximum of 4 concurrent arrangements (APRNs and PAs combined)
Clinics Also Need to Understand Indiana Collaboration Requirements
While this guide primarily covers the responsibilities and compliance requirements placed on collaborating physicians in Indiana, these regulations directly affect APRN-owned clinics, medspas, and healthcare practices that depend on physician collaboration to operate. In many cases, clinic owners researching Indiana collaboration rules are also trying to understand how to find a qualified physician who is within geographic proximity of the clinic, has capacity for another arrangement within the four-provider cap, and is prepared to fulfill the weekly chart review obligation that Indiana specifically requires.
Need Help Finding an Indiana Collaborating Physician?
For clinics, understanding the legal requirements is only one part of the process. The next challenge is finding a qualified physician who has the capacity to conduct weekly chart reviews for another active arrangement, understands that prescribing cannot begin until ISBN issues approval, and will maintain the documentation habits the biennial audit program requires. Whether you are launching a new clinic, replacing a physician whose agreement has been terminated, or managing the immediate notification obligation triggered by a change in physician prescriptive authority, having the right physician in place is essential.
If your clinic is actively looking for an Indiana collaborating physician, our team can match you with a qualified physician, often within 24 to 48 hours. We work with clinics across Indiana to simplify the physician matching process while supporting CPA drafting, ISBN Cover Sheet submissions, and long-term collaboration needs.
Final Thoughts
Indiana collaborating physician requirements are built around a board-approval prerequisite that makes the agreement effective only after the ISBN issues prescriptive authority, a weekly chart review obligation that is more frequent than any other state in this series, and a biennial audit program that gives the state an active ongoing compliance verification mechanism. For physicians entering the Indiana market, the most important steps are confirming that the ISBN approval is received before the APRN prescribes, establishing the weekly review process from day one, staying within the four-provider cap, and maintaining organized documentation that can withstand an audit.
Build a Compliant Indiana Collaboration With Collaborating Physician
Are you looking for a collaborating physician role in Indiana? If you are a licensed Indiana 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 Indiana and 50-plus other states. Every arrangement is built to meet state-specific requirements, including Indiana’s CPA submission and approval process under IC § 25-23-1-19.4, the Cover Sheet filing obligation, the weekly 5% chart review standard under 848 IAC 5-1-1, the four-provider ratio cap, and the biennial audit documentation requirements. Physicians receive compliance support throughout the collaboration, not just at the start. Applications take under ten minutes. Clinic matches typically happen within 24 to 48 hours. There is no cost to physicians at any stage.
If you are a clinic owner who found this page, we have something for you as well. Collaborating Physician also matches Indiana clinics with qualified, vetted collaborating physicians who are within geographic proximity of your practice, have capacity within the four-provider cap, and understand the weekly chart review obligations and board approval timeline. Whether you are launching a new clinic and waiting on ISBN prescriptive authority approval, replacing a physician whose CPA has been terminated, or managing the immediate change notification requirements, 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. Indiana healthcare regulations are under active legislative review in 2025 and 2026. Always verify current requirements directly with the Indiana State Board of Nursing, the Indiana Medical Licensing Board, and a qualified healthcare attorney before making any practice decisions.
Frequently Asked Questions
Can an Indiana APRN begin prescribing as soon as the CPA is signed?
No. The collaborative practice agreement must be submitted to the Indiana State Board of Nursing with the APRN’s prescriptive authority application and mandatory Cover Sheet. Written practice agreements are not valid for prescriptive authority purposes until the ISBN issues approval. The APRN may not write any prescription until the ISBN approval letter has been received.
How often must an Indiana collaborating physician review the APRN’s charts?
Under 848 IAC 5-1-1, the physician must review at least a 5% random sampling of charts and medications the APRN has prescribed for patients on a weekly basis. The APRN submits documentation to the physician within seven days, and the physician must complete the review within seven days of receipt.
How many APRNs can one Indiana physician collaborate with?
A physician cannot collaborate with more than four APRNs or PAs simultaneously. This cap applies across all active arrangements combined. A physician with two APRN agreements and two PA agreements has reached the maximum and cannot enter a fifth arrangement without ending one of the existing ones.
Does Indiana require geographic proximity between the physician and the APRN?
Yes. Geographic proximity between the APRN and the collaborating physician is required under Indiana law and must be addressed in the practice agreement. However, a specific mileage limit is not numerically defined in state code or administrative rules.
What controlled substance registrations does an Indiana APRN need?
An APRN prescribing controlled substances must obtain an Indiana Controlled Substances Registration from the Indiana Professional Licensing Agency and a federal DEA registration. Both must be active before any controlled substance prescription may be written.
What happens during Indiana’s biennial audit program?
The Indiana Professional Licensing Agency randomly audits between 1% and 10% of active practice agreements before December 31 of each even-numbered year. The audit verifies compliance with board requirements, including the agreement documentation, chart review records, and prescriptive authority approval. Physicians selected for audit must be able to produce organized, complete compliance documentation.
