New York collaborating physician requirements apply to a large and active market with more than 34,000 licensed nurse practitioners as of 2024. New York is a transitional practice state, meaning the physician collaboration requirement is tied to the NP’s hours of experience rather than being a permanent, career-long obligation. NPs with fewer than 3,600 hours of qualifying practice must operate under a written practice agreement with a collaborating physician. NPs who have completed 3,600 or more hours move into a different framework that requires collaborative relationships but not a formal written agreement.
For physicians entering a New York collaboration role, understanding which framework applies to a specific NP, what the written practice agreement must contain, and what the ongoing oversight obligations look like is essential before signing anything. This guide covers every requirement a physician needs to understand in 2026, sourced directly from New York Education Law § 6902 and current board guidance.
New York Collaborating Physician Overview: Where New York Stands
New York’s framework for NP practice is governed by New York State Education Law § 6902 and administered by the New York State Education Department (NYSED). The state holds NPs independently responsible for the diagnosis and treatment of their patients and does not require an NP to practice under physician supervision. However, NPs who have not yet completed 3,600 hours of qualifying experience must practice in accordance with written practice protocols and a written practice agreement with a collaborating physician.
Governing Body
The New York State Education Department, Office of the Professions governs NP certification, written practice agreement requirements, and practice protocol standards. Disciplinary matters involving physicians in collaborative arrangements are handled through the New York State Board for Medicine.
The Nurse Practitioner Modernization Act
The Nurse Practitioner Modernization Act (NPMA), enacted in 2022, established the current transitional framework. Key provisions of the NPMA are subject to a sunset clause that has been extended and is currently set to expire July 1, 2026. New York Senate Bill S2360, introduced in January 2025, proposes to make the NPMA permanent and expand collaboration options for new NPs to include experienced NPs in addition to physicians. Physicians entering New York collaboration arrangements in 2026 should monitor the status of S2360, as its outcome will affect the framework governing agreements entered into or renewed after July 1, 2026.
The Two-Tier Framework: Under 3,600 Hours vs. Over 3,600 Hours
New York’s practice structure depends entirely on where the NP falls relative to the 3,600-hour threshold.
Tier 1: Under 3,600 Hours (Written Practice Agreement Required)
An NP who has not yet completed 3,600 hours of qualifying experience must practice in accordance with both a written practice agreement with a collaborating physician and written practice protocols. The collaborating physician must be qualified to practice in the NP’s specialty area. This is the framework under which physician collaboration arrangements are entered into in New York.
Qualifying experience includes hours practiced as a licensed or certified NP in New York State, another state, working as an NP for the United States Veterans Administration, the United States Armed Forces, or the United States Public Health Service.
Tier 2: Over 3,600 Hours (Collaborative Relationships, Not Written Agreement)
An NP who has completed more than 3,600 hours of qualifying experience is not required to have a written practice agreement or written practice protocols. Instead, this NP must maintain collaborative relationships with one or more licensed physicians qualified to collaborate in the specialty involved, or with a hospital licensed under Article 28 of the Public Health Law. A collaborative relationship at this tier means communicating, as needed, with the qualified physician for the purposes of exchanging information in order to provide comprehensive patient care and to make referrals.
NPs at this tier file the NP-CR Collaborative Relationships Attestation Form with the NYSED and maintain documentation of their collaborative relationships for inspection upon request. A physician who collaborates informally with an experienced NP at this tier should understand that the arrangement is not governed by the same written agreement requirements as Tier 1.
The Written Practice Agreement: New York’s Core Compliance Document
For NPs practicing under Tier 1 (under 3,600 hours), the written practice agreement is the foundational legal document governing the collaboration. The agreement must be entered into with a physician who is qualified to practice in the NP’s specialty area of practice.
A copy of the agreement must be kept at the NP’s practice setting and made available for inspection by the New York State Education Department. There is no requirement to file the written practice agreement itself with any state board. The agreement is maintained on-site and produced on request.
What Must Be in a New York Practice Agreement
New York Education Law § 6902 specifies the required elements of a valid written practice agreement. The agreement must address all of the following:
1. Patient Referral and Consultation
The agreement must include provisions addressing when and how the NP will refer patients to or consult with the collaborating physician. The process for consultation and referral must be clearly described.
2. Emergency Coverage
The agreement must address coverage for emergency absences of either the NP or the collaborating physician. When either party is unavailable, the agreement must describe how continuity of care and oversight are maintained.
3. Disagreement Resolution
The agreement must include explicit provisions for the resolution of any disagreement between the NP and the collaborating physician regarding a matter of diagnosis or treatment within the scope of practice of both. If the practice agreement does not address this, the collaborating physician’s diagnosis or treatment shall prevail by operation of law.
4. Peer Review and Chart Review
The agreement must provide for peer review by the collaborating physician of patient records in a timely fashion, but no less often than every three months. New York State law does not specify the minimum number or percentage of charts that must be reviewed. The frequency floor is quarterly, but the scope of review is determined by the parties.
Practice Protocols: Filing and Maintenance Requirements
In addition to the written practice agreement, New York requires NPs practicing under Tier 1 to operate in accordance with written practice protocols.
Current Requirements (Until July 1, 2026)
The practice protocol must reflect current accepted medical and nursing practice and may be updated periodically. Under current law, the protocol does not need to be filed with the NYSED before the collaboration begins.
New Requirements (Effective July 1, 2026)
Under Education Law § 6902 provisions taking effect July 1, 2026, the practice protocols must be filed with the NYSED department within 90 days of the commencement of practice. Physicians entering new collaboration arrangements in 2026 should confirm with the NP that the protocol filing obligation is being met within this window.
The NYSED offers recommended practice protocols on its website, which serve as a resource for NPs developing their own protocols. Protocols must identify the area of practice, reflect accepted standards of nursing and medical practice, and include provisions for case management including diagnosis, treatment, and appropriate record keeping.
The names of both the NP and the collaborating physician must be clearly posted in the practice setting of the NP.
Physician Eligibility and the Specialty Alignment Standard
A New York collaborating physician must hold a current, active license to practice medicine in New York State. The physician must be qualified to practice in the NP’s specialty area of practice. This specialty alignment requirement is statutory, not discretionary.
New York certifies NPs to practice in specific specialty areas, including Acute Care, Adult Health, College Health, Community Health, Family Health, Gerontology, Holistic Care, Neonatology, Obstetrics, Oncology, Palliative Care, Pediatrics, Perinatology, Psychiatry, School Health, and Women’s Health.
A physician entering a collaboration agreement must have the qualifications and clinical background to collaborate in the specific specialty in which the NP is certified. A family medicine physician can collaborate with a family health NP. Collaborating with a psychiatric NP requires clinical qualifications in that specialty. This is not simply a best-practice recommendation. It is a statutory requirement under Education Law § 6902.
Prescriptive Authority and Controlled Substances in New York
NPs practicing under a written practice agreement in New York may prescribe prescription drugs and controlled substances within the scope of their specialty area and the terms of the practice agreement.
Prescription Form Requirements
Prescription forms used by NPs practicing under a written practice agreement must be printed with the name, NP certificate number, office address, and office telephone number of the NP.
Controlled Substances
NPs in New York may prescribe Schedule II through V controlled substances with a valid DEA registration, within the specialty area of their certification and consistent with the practice agreement. There is no blanket prohibition on Schedule II prescribing for New York NPs practicing under a physician agreement, which distinguishes New York significantly from states like Georgia and Missouri.
The Physician-to-NP Ratio: New Rules Effective July 2026
New York Education Law § 6902 includes a physician-to-NP ratio provision that takes effect July 1, 2026.
The Incoming Ratio Rule
Effective July 1, 2026, no physician shall enter into practice agreements with more than four nurse practitioners who are not located on the same physical premises as the collaborating physician. This limit applies to off-site NPs only. NPs who practice at the same physical location as the collaborating physician are not counted toward this cap.
Physicians who currently collaborate remotely with more than four NPs in New York should review their active arrangements before July 1, 2026, to ensure compliance with the incoming ratio rule. New agreements entered after that date are subject to this limit from the start.
Fee Splitting and Kickback Prohibitions
New York Education Law and NYSED regulations prohibit a collaborating physician and an NP from engaging in fee splitting or kickbacks. These prohibitions are designed to ensure that medical and nursing decisions are based on sound clinical judgment, not economic arrangements.
What This Means in Practice
- A physician may not pay an NP a fee in exchange for patient referrals to the physician.
- An NP may not share practice income or fees with a physician who is not the NP’s employer in exchange for the collaboration agreement itself.
- A collaboration fee arrangement in which the NP pays the physician a percentage of practice revenue constitutes fee splitting under New York law.
These prohibitions do not prevent physicians from receiving fair compensation for their time and oversight obligations. They prevent compensation structures that are tied to referral patterns or revenue sharing. Physicians entering New York collaboration arrangements should ensure their compensation structure is structured as a flat fee for services rendered, not as a percentage of the NP’s practice revenue.
The Legislative Landscape: What S2360 Means for Physicians
New York Senate Bill S2360, introduced in January 2025, proposes two significant changes to the current framework that physicians should monitor:
- Making the NPMA permanent. Without S2360 or similar legislation, the provisions of the Nurse Practitioner Modernization Act expire July 1, 2026. If the Act expires, NPs who have completed 3,600 hours would again be required to enter into written practice agreements rather than maintaining informal collaborative relationships.
- Expanding collaboration options for new NPs. S2360 would allow NPs with fewer than 3,600 hours to enter into written practice agreements with either a qualified physician or an experienced NP (one with 3,600+ hours of experience), rather than exclusively with a physician.
Physicians currently in active practice agreements with NPs approaching the 3,600-hour threshold should track the legislative status of S2360. If the NPMA is not made permanent before July 1, 2026, the practice landscape for experienced NPs in New York will change significantly.
Common Compliance Mistakes New York Collaborating Physicians Make
Most compliance problems in New York NP collaboration arrangements come from specialty mismatches, inadequate agreement terms, and missed protocol obligations.
- Specialty mismatch between physician and NP. The physician must be qualified to practice in the NP’s certified specialty area. A physician who enters an agreement with a psychiatric NP without psychiatric qualifications is not meeting the statutory eligibility standard.
- Agreement does not address disagreement resolution. If the written practice agreement does not include an explicit provision for resolving disagreements about diagnosis or treatment, New York law defaults to the collaborating physician’s determination prevailing. Physicians should ensure this provision is stated clearly to avoid ambiguity.
- Chart review not conducted quarterly. The practice agreement must provide for peer review no less often than every three months. Physicians who allow review to lapse beyond the quarterly minimum are not in compliance regardless of the absence of a minimum chart count requirement.
- Protocol not filed within 90 days (from July 2026). Beginning July 1, 2026, the practice protocol must be filed with the NYSED within 90 days of the commencement of practice. Physicians entering new arrangements after that date should confirm with the NP that the protocol filing is completed within the required window.
- Ratio exceeded for remote NPs (from July 2026). Effective July 1, 2026, a physician may not enter into practice agreements with more than four NPs not located on the same physical premises. Physicians currently collaborating remotely with five or more NPs need to assess their arrangements before the new limit takes effect.
- Fee splitting structure in the compensation arrangement. New York prohibits compensation structures that tie the physician’s payment to a percentage of the NP’s practice revenue. Agreements that are structured this way violate New York law regardless of how they are labeled.
New York Collaborating Physician Requirements: Quick Reference
Practice Authority Framework
- Transitional practice state: NPs under 3,600 hours require written practice agreement with a physician
- NPs over 3,600 hours: written agreement not required; collaborative relationships maintained and attested on NP-CR form
Physician Eligibility
- Active New York MD or DO license
- Must be qualified to practice in the NP’s certified specialty area
Core Compliance Document (Under 3,600 Hours)
- Written practice agreement maintained on-site at the NP’s practice setting
- Must address: referral and consultation, emergency coverage, disagreement resolution, quarterly chart review
- Agreement not filed with state; available for NYSED inspection on request
Practice Protocols
- Must reflect current accepted medical and nursing practice
- Effective July 1, 2026: protocols filed with NYSED within 90 days of commencement of practice
- NP and physician names conspicuously posted at practice setting
Chart Review
- Quarterly minimum; no minimum chart count specified by law
Physician-to-NP Ratio
- Effective July 1, 2026: maximum of 4 NPs per physician who are not on the same physical premises
Prescriptive Authority
- NPs may prescribe Schedule II through V controlled substances with valid DEA registration
- No blanket Schedule II prohibition (differs significantly from Georgia and Missouri)
Fee Splitting
- Prohibited; physician compensation must not be structured as a percentage of NP practice revenue
Geographic Requirement
- None specified; no proximity requirement for Tier 1 NPs
Clinics Also Need to Understand New York Collaboration Requirements
While this guide primarily covers the responsibilities and compliance requirements placed on collaborating physicians in New York, these regulations directly affect NP-owned clinics, medspas, and healthcare practices that depend on physician collaboration to operate. In many cases, clinic owners researching New York collaboration rules are also trying to understand how to find a qualified physician who meets the specialty alignment requirement and is prepared to fulfill the quarterly chart review and practice agreement obligations under Education Law § 6902.
Need Help Finding a New York Collaborating Physician?
For clinics, understanding the legal requirements is only one part of the process. The next challenge is finding a qualified physician who is available, responsive, certified in a comparable specialty to the NP, and familiar with New York practice agreement compliance expectations. Whether you are launching a new NP-operated clinic, expanding an existing practice, or approaching the July 2026 protocol filing deadline and need a compliant agreement in place, having the right physician relationship is essential for operating smoothly and remaining compliant.
If your clinic is actively looking for a New York collaborating physician, our team can match you with a qualified physician, often within 24 to 48 hours. We work with clinics across New York to simplify the physician matching process while supporting onboarding, agreement drafting, protocol documentation, and long-term collaboration needs.
Final Thoughts
New York collaborating physician requirements reflect a state that has moved meaningfully toward NP independence while maintaining a structured oversight framework for early-career practitioners. The 3,600-hour threshold is the defining feature of the New York model, and the collaboration requirements for NPs below that threshold are specific, documented, and enforceable by the NYSED.
For physicians entering the New York market, the most important steps are confirming specialty alignment, drafting a practice agreement that addresses all required elements, and maintaining a quarterly chart review process from the start. With the July 2026 protocol filing requirement and the incoming ratio cap for remote NPs also approaching, physicians with existing or planned New York arrangements should review their documentation against the updated requirements before those provisions take effect.
Build a Compliant New York Collaboration With Collaborating Physician
Are you looking for a collaborating physician role in New York? If you are a licensed New York physician interested in a structured, compliant collaboration arrangement with an NP-operated clinic, Collaborating Physician handles the infrastructure so you do not have to navigate it alone. The platform connects licensed physicians with vetted clinics across New York and 50-plus other states. Every agreement is structured to meet state-specific requirements, including New York’s specialty alignment standard, written practice agreement elements under Education Law § 6902, quarterly chart review obligations, and the July 2026 protocol filing and ratio 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 New York clinics with qualified, vetted collaborating physicians who meet the specialty alignment requirement and are ready to enter into properly drafted practice agreements. Whether you are launching a new clinic with an NP under 3,600 hours, approaching the July 2026 protocol filing deadline, or replacing a physician whose agreement is ending, 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. New York healthcare regulations change frequently, and provisions of the Nurse Practitioner Modernization Act are subject to legislative action before July 1, 2026. Always verify current requirements directly with the New York State Education Department Office of the Professions and a qualified healthcare attorney before making any practice decisions.
Frequently Asked Questions
Does a New York collaborating physician need to be physically present at the NP’s clinic?
No. New York does not impose a geographic proximity requirement on collaborating physicians. The NP does not need to share office space or work in the same building as the physician. The practice agreement must address coverage for emergency absences and consultations, but physical co-location is not required.
How many NPs can one New York physician collaborate with?
Effective July 1, 2026, no physician may enter into written practice agreements with more than four NPs who are not located on the same physical premises as the physician. NPs who practice at the same physical location as the collaborating physician are not counted toward this limit. There is currently no cap for NPs on the same premises.
When does a New York NP no longer need a written practice agreement?
After completing 3,600 hours of qualifying NP practice experience, an NP is no longer required to have a written practice agreement or written practice protocols with a collaborating physician. The NP must instead maintain collaborative relationships with qualified physicians and file the NP-CR Collaborative Relationships Attestation Form with the NYSED. This threshold applies to experience accumulated across New York, other states, and federal service settings.
Does New York allow NPs to prescribe Schedule II controlled substances?
Yes. Unlike Georgia and Missouri, New York does not impose a blanket prohibition on Schedule II prescribing for NPs practicing under a written practice agreement. NPs with a valid DEA registration may prescribe Schedule II through V controlled substances within the scope of their specialty area and the terms of their practice agreement.
Does a New York practice agreement need to be filed with the state?
The written practice agreement does not need to be filed with any state board. It must be kept at the NP’s practice setting and made available for inspection by the NYSED upon request. Effective July 1, 2026, practice protocols must be filed with the NYSED within 90 days of the commencement of practice.
What is the specialty alignment requirement for New York collaborating physicians?
The collaborating physician must be qualified to practice in the NP’s certified specialty area of practice. This is a statutory requirement under Education Law § 6902. A physician entering a collaboration with a psychiatric NP must have clinical qualifications in psychiatry. Specialty alignment is not discretionary and cannot be waived by agreement of the parties.
