Vermont collaborating physician requirements apply to a transitional-practice state with one of the most precisely defined hours-and-months thresholds in the country for nurse practitioners and certified nurse midwives, paired with a fully separate and permanent physician collaboration framework for physician assistants. Under 26 V.S.A. § 1613, an APRN with fewer than 24 months and 2,400 hours of licensed active advanced nursing practice in an initial role and population focus must maintain a formal agreement with a collaborating provider. Vermont’s collaborating provider may be either a physician or an experienced APRN, a flexibility that distinguishes Vermont from many states that require the partner to be a physician specifically.
For physicians in Vermont, the active collaboration market includes both the transitional NP and CNM period and the fully ongoing PA practice agreement framework, which remains in effect regardless of a PA’s years of experience. This guide covers both frameworks physicians need to understand in 2026.
Vermont Collaborating Physician Overview: Where Vermont Stands
Vermont is classified as a full-practice-authority state once the transition-to-practice requirement is satisfied, though some industry trackers classify it among states using a defined hours-and-months threshold model similar to New York, Wisconsin, and California. The Vermont Board of Nursing has sole regulatory oversight of APRN licensure, the collaborative provider agreement requirement, and the transition to independent practice, under 26 V.S.A. Chapter 28. The Vermont Board of Medical Practice governs physician licensure and participates in matters relating to APRN regulation through a standing subcommittee structure described later in this guide. Physician assistants in Vermont are governed under a separate statutory framework at 26 V.S.A. § 1735a.
The 2,400-Hour and 24-Month Transition to Practice Threshold
Under 26 V.S.A. § 1613(a)(1), an APRN with fewer than 24 months and 2,400 hours of licensed active advanced nursing practice in an initial role and population focus shall have a formal agreement with a collaborating provider as required by Board rule. Both the time threshold and the hours threshold must be satisfied; reaching one without the other does not complete the transition requirement.
Documentation Obligations
An APRN shall have and maintain signed and dated copies of all required collaborative provider agreements. This retention obligation applies throughout the transitional period and is the APRN’s documentation responsibility, though the collaborating provider should likewise retain their own copy as part of sound practice.
Additional Role and Population Focus: The Reduced 1,600-Hour Standard
Vermont’s statute also addresses APRNs who are adding an additional role and population focus beyond their initial credential. Under 26 V.S.A. § 1613(a)(1), an APRN with fewer than 12 months and 1,600 hours of licensed active advanced nursing practice for any additional role and population focus shall likewise have a formal agreement with a collaborating provider. This reduced threshold recognizes that an APRN who has already completed the full transition-to-practice requirement in one population focus does not need to repeat the entire 2,400-hour standard when adding a second credential, but does need a shorter, focused collaborative period specific to the new role.
Who Can Serve as the Collaborating Provider in Vermont
Vermont’s statutory language and supporting guidance describe the collaborating partner as either a physician or an experienced APRN. A collaborating APRN must have the same role and population focus as the APRN being collaborated with, ensuring the partner has genuinely relevant clinical background for the specific transition period at issue.
Physician Eligibility
A collaborating physician should be licensed in Vermont and have a clinical background relevant to the APRN’s role and population focus. Vermont’s Board of Nursing rules implementing 26 V.S.A. § 1613 further define the specific qualifications expected of the collaborating provider, and physicians considering this role should consult current Board of Nursing rule language for the complete eligibility criteria.
The Board of Medical Practice’s Role in APRN Regulation
Vermont’s statute requires the Board of Nursing to appoint a subcommittee to study and report on matters relating to APRN practice. That subcommittee must include at least five members, a majority of whom are APRNs licensed and in good standing in Vermont, at least one public member, and at least one physician designated by the Board of Medical Practice. This structure ensures ongoing physician input into the regulatory framework that governs APRN collaboration, even though individual collaborating providers are not required to come through this subcommittee process.
What the Vermont Collaborative Provider Agreement Must Establish
While the core statutory provision at 26 V.S.A. § 1613 sets the hours-and-months thresholds and the requirement for a formal agreement, the specific content requirements for that agreement are further defined by Vermont Board of Nursing rule. At minimum, Vermont’s transition-to-practice framework anticipates that the collaborative provider agreement will establish the working relationship between the APRN and the collaborating provider, identify the collaborating provider by name, and document the start of the collaborative period so that progress toward the 2,400-hour or 1,600-hour threshold can be tracked and verified.
Solo Practice Limitation Tied to the Agreement
An APRN required to practice with a collaborative provider agreement may not engage in solo practice, except with regard to a role and population focus in which the APRN has already met the transition-to-practice requirements of this subsection. This means an APRN who has completed the threshold for one population focus but is adding a new one under the 1,600-hour standard may continue solo practice in the already-qualified focus area while completing the additional collaborative period for the new credential.
Notifying the Board: How the Transition to Independence Works
Under 26 V.S.A. § 1613(b), an APRN who satisfies the requirements to engage in solo practice shall notify the Board that these requirements have been met. This notification is the formal mechanism by which the collaborative period ends and the APRN’s independent practice status is recognized by the Board of Nursing.
What This Means for Physicians
The collaborating provider’s role in Vermont concludes when the APRN has accumulated the required hours and months and has notified the Board. Physicians serving as collaborating providers should maintain accurate, dated records of the collaborative relationship to support the APRN’s eventual notification to the Board, since that notification relies on demonstrable completion of both thresholds.
The Solo Practice Restriction During the Collaborative Period
The restriction on solo practice during the collaborative period is a meaningful operational detail for both the APRN and the collaborating provider. An APRN who has not yet met the 2,400-hour and 24-month threshold, or the applicable 1,600-hour and 12-month threshold for an additional focus, cannot establish or operate a standalone independent practice. This means clinics employing newly licensed Vermont APRNs must structure the practice setting so the APRN is genuinely operating within a collaborative relationship, not functioning as the sole independent provider at a location.
Exceptions Where No Formal Collaboration Is Required
Vermont’s statute carves out specific clinical circumstances where the formal collaborative agreement structure does not apply to a given prescribing act, even for an APRN who is otherwise within the transitional period. These exceptions include prescribing for a patient examined by a licensed APRN, physician assistant, or other practitioner authorized by law and supported by the APRN; prescribing medication for an individual to terminate a pregnancy based on an adaptive questionnaire developed in consultation with appropriately qualified health care providers, under 18 V.S.A. chapter 223; continuing medication on a short-term basis for a new patient prior to the patient’s first appointment; and emergency situations where the life or health of the patient is in imminent danger.
Why These Exceptions Matter
These statutory exceptions recognize that certain clinical situations require flexibility regardless of where an individual APRN stands in their transition-to-practice timeline. They do not eliminate the general collaborative agreement requirement; they identify specific prescribing scenarios that fall outside its scope.
The Emergency Waiver Provision
Under 26 V.S.A. § 1613(c), the Board may waive or modify the collaborative provider agreement requirement as necessary to allow an APRN to practice independently during a declared state of emergency. This gives Vermont’s Board of Nursing flexibility to temporarily suspend the transition-to-practice requirement when a declared emergency creates an urgent need for expanded independent APRN practice capacity.
Where Physician Collaboration Also Applies: The PA Framework
Physician assistants in Vermont are governed by an entirely separate and permanent collaboration framework under 26 V.S.A. § 1735a. Unlike the APRN model, which is transitional and ends once the hours-and-months threshold is met, Vermont’s PA practice agreement requirement applies for the duration of the PA’s practice, regardless of years of experience.
The Core PA Requirement
A PA shall engage in practice as a PA in Vermont only if the PA has entered into a written practice agreement. Vermont does not provide an experience-based exemption from this requirement in the way the APRN framework does; every practicing Vermont PA must have a practice agreement in place with a participating physician.
What the Vermont PA Practice Agreement Must Contain
Under 26 V.S.A. § 1735a, a practice agreement shall include all of the following:
1. Processes for Physician Communication and Joint Evaluation
The agreement must establish processes for physician communication, availability, decision-making, and periodic joint evaluation of services delivered when providing medical care to a patient.
2. Scope of Practice Limited to the PA’s Education, Training, and Experience
The agreement must include an agreement that the PA’s scope of practice shall be limited to medical care that is within the PA’s education, training, and experience. Specific restrictions, if any, on the PA’s practice shall be listed in the agreement.
3. A Plan for Physician Availability for Consultation at All Times
The agreement must include a plan to have a physician available for consultation at all times when the PA is practicing medicine. This availability obligation is continuous throughout the PA’s active practice hours, not limited to scheduled check-ins.
4. Signatures of the PA and the Participating Physician
The agreement must be signed by the PA and the participating physician; no other signatures shall be required. This is a notably streamlined signature requirement compared to states that require additional administrative or facility signatures.
Physician Eligibility for PA Collaboration in Vermont
Adaptable Proximity Standard
Vermont statute allows adaptable proximity for PA collaboration. A practice agreement may specify the extent of the collaboration required between the PA and physicians and other health care professionals; provided, however, that a physician shall be accessible for consultation by telephone or electronic means at all times when a PA is practicing. This means there is no fixed geographic distance requirement, but the availability standard itself is continuous and active.
No Statutory Ratio Limit
Vermont does not currently have any provisions related to the number of PAs a physician can supervise or collaborate with. This gives Vermont physicians and PA-employing practices more flexibility in structuring multi-PA collaborative arrangements than states with explicit numerical caps.
No Chart Review or Co-Signature Mandate
Vermont does not currently have any provisions related to chart review or chart co-signatures for PA practice agreements. The periodic joint evaluation of services described in the practice agreement itself is the operative oversight mechanism, rather than a separately mandated chart review percentage or frequency standard.
Delegation Must Match the PA’s Competence
The delegation agreement must identify the PA’s scope of practice and confirm that the delegation of medical care is appropriate to the PA’s level of competence. All medical care must be delegated by the supervising physician, meaning the PA’s authorized scope flows directly from what the physician has determined is appropriate to delegate.
Prescriptive Authority in Vermont
APRN and CNM Prescribing
Vermont APRNs, including certified nurse midwives, may prescribe medical, therapeutic, or corrective measures under administrative rules adopted by the Vermont Board of Nursing. During the transitional collaborative period described above, this prescriptive authority operates within the collaborative agreement structure; once the APRN has completed the 2,400-hour and 24-month threshold and notified the Board, prescriptive authority continues without the collaborative requirement.
Nurse Practitioner and Nurse Midwife Signature Authority
Under 26 V.S.A. § 1616, whenever any provision of Vermont statute, rule, or any form requires a signature, certification, stamp, verification, affidavit, or other endorsement by a physician, that requirement is deemed to include the equivalent endorsement by a licensed APRN certified as a nurse practitioner or nurse midwife, provided this does not expand the APRN’s underlying scope of practice. This is a broadly applicable provision that affects how NPs and CNMs interact with forms and documentation across many areas of Vermont law, not solely the collaborative agreement context.
PA Prescribing
Vermont PAs may prescribe medications, including those addressed in the practice agreement, consistent with the scope of practice the supervising physician has delegated. The practice agreement’s content requirements, including the limitation to the PA’s education, training, and experience, govern the PA’s authorized prescribing scope.
Common Compliance Mistakes Vermont Collaborating Physicians Make
Physicians and APRNs sometimes assume the 2,400-hour and 24-month thresholds are interchangeable or that meeting one alone is sufficient. Both the hours and the months must be satisfied before the collaborative requirement ends for the initial role and population focus.
The reduced 1,600-hour standard for an additional role and population focus is sometimes overlooked, with parties applying the full 2,400-hour standard unnecessarily, or conversely failing to recognize that a new population focus still requires its own qualifying collaborative period even though the APRN is already independently practicing in their original focus area.
For PA practice agreements, physicians sometimes assume that ongoing chart review or co-signature documentation is required, since this is common in many other states. Vermont does not currently impose such a requirement, though the periodic joint evaluation of services described in the agreement remains a meaningful, ongoing obligation that should not be neglected simply because no specific percentage is statutorily mandated.
Physicians occasionally treat the PA collaboration requirement as something that diminishes with the PA’s years of experience, similar to the APRN transition-to-practice model. Vermont’s PA framework does not include this experience-based exemption; the written practice agreement remains required regardless of how many years the PA has practiced.
The continuous availability standard for PA consultation is sometimes treated loosely. The statute requires that a physician be accessible for consultation by telephone or electronic means at all times when a PA is practicing, not merely during a portion of the PA’s working hours.
Vermont Collaborating Physician Requirements: Quick Reference
APRN and CNM Transition-to-Practice Framework
An APRN with fewer than 24 months and 2,400 hours of licensed active advanced nursing practice in an initial role and population focus needs a formal collaborative provider agreement. An APRN with fewer than 12 months and 1,600 hours for an additional role and population focus needs the same for that additional credential. Collaborating provider may be a physician or an experienced APRN with the same role and population focus. APRN notifies the Board once thresholds are met to begin solo practice.
Documentation
Signed and dated copies of all required collaborative provider agreements must be maintained by the APRN.
Solo Practice Restriction
An APRN under a required collaborative agreement may not engage in solo practice except in a role and population focus where the threshold has already been met.
Statutory Exceptions
No formal collaboration required for prescribing supported by another authorized practitioner’s examination, certain pregnancy termination medication prescribing under 18 V.S.A. chapter 223, short-term continuation of medication for a new patient before their first appointment, and genuine emergencies.
Emergency Waiver
The Board may waive or modify the collaborative provider agreement requirement during a declared state of emergency.
PA Framework (Permanent, Not Transitional)
Written practice agreement required for every practicing Vermont PA regardless of years of experience, under 26 V.S.A. § 1735a. Agreement must address physician communication and joint evaluation processes, scope limited to PA’s education and training, a plan for physician availability at all times, and signatures of only the PA and participating physician.
PA Collaboration Standards
Adaptable proximity; physician must be accessible by telephone or electronic means at all times when the PA is practicing. No statutory ratio limit on PAs per physician. No chart review or co-signature mandate.
Clinics Also Need to Understand Vermont Collaboration Requirements
While this guide primarily covers the physician collaboration requirements in Vermont, these regulations directly affect APRN-operated clinics during the transitional period and PA-operated practices on an ongoing basis. In many cases, clinic owners researching Vermont collaboration rules are trying to understand exactly where their APRN stands relative to the 2,400-hour and 24-month threshold, or are establishing the written PA practice agreement that Vermont requires for the full duration of a PA’s career in the state.
Need Help Finding a Vermont Collaborating Physician?
For clinics with APRNs still in the transition-to-practice period, the next challenge is finding a qualified collaborating provider, whether a physician or an experienced APRN with the same role and population focus, who is prepared to maintain accurate documentation supporting the eventual Board notification. For clinics employing PAs, the challenge is establishing and maintaining a compliant written practice agreement that addresses all four required elements and ensures genuine physician availability at all times the PA is practicing. Whether you are launching a new clinic with a newly licensed APRN, onboarding a PA for the first time, or confirming that your practice agreements reflect current scope and restrictions, having the right physician relationship in place matters.
If your clinic is actively looking for a Vermont collaborating physician, our team can match you with a qualified physician, often within 24 to 48 hours. We work with clinics across Vermont to simplify the physician matching process while supporting collaborative provider agreement and PA practice agreement drafting, hours and months tracking, and long-term collaboration needs.
Final Thoughts
Vermont collaborating physician requirements reflect a state that distinguishes clearly between a transitional model for APRNs and CNMs, built around the 2,400-hour and 24-month threshold with a reduced standard for additional population foci, and a permanent collaboration model for PAs that does not diminish with experience. The flexibility to use an experienced APRN as the collaborating provider, the adaptable proximity standard for PA consultation, and the absence of chart review mandates or PA ratio limits all make Vermont a comparatively streamlined state to navigate once the underlying framework is understood.
For physicians entering the Vermont market, the most important steps are confirming whether the relationship is the transitional APRN model or the permanent PA model, tracking hours and months accurately to support eventual Board notification for APRN collaborations, and ensuring PA practice agreements address all four statutorily required elements with genuine, continuous availability for consultation.
Build a Compliant Vermont Collaboration With Collaborating Physician
Are you looking for a collaborating physician role in Vermont? If you are a licensed Vermont physician interested in a structured, compliant collaboration arrangement with an APRN or PA-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 Vermont and 50-plus other states. Every arrangement is built to meet state-specific requirements, including Vermont’s 2,400-hour and 24-month transition-to-practice framework under 26 V.S.A. § 1613, the reduced 1,600-hour standard for additional population foci, the permanent PA practice agreement requirements under 26 V.S.A. § 1735a, and the continuous availability standard for PA consultation. 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 Vermont clinics with qualified, vetted collaborating physicians who understand both the APRN transition-to-practice model and the permanent PA practice agreement framework. Whether you are launching a new clinic with a newly licensed APRN, onboarding your first PA, or confirming your existing agreements reflect current scope and documentation 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. Vermont healthcare regulations change frequently. Always verify current requirements directly with the Vermont Board of Nursing, the Vermont Board of Medical Practice, and a qualified healthcare attorney before making any practice decisions.
Frequently Asked Questions
Does every Vermont APRN need a collaborating physician?
Only during the transitional period. Under 26 V.S.A. § 1613, an APRN with fewer than 24 months and 2,400 hours of licensed active advanced nursing practice in an initial role and population focus must have a formal agreement with a collaborating provider. Once both thresholds are met and the APRN notifies the Board, the APRN may engage in solo practice without a collaborating provider.
Does the Vermont collaborating provider have to be a physician?
No. Vermont’s framework allows the collaborating provider to be either a physician or an experienced APRN who has the same role and population focus as the APRN being collaborated with. This flexibility distinguishes Vermont from states that require the collaborating partner to be a physician specifically.
What happens when a Vermont APRN adds an additional population focus?
A reduced threshold applies. Under 26 V.S.A. § 1613, an APRN with fewer than 12 months and 1,600 hours of licensed active advanced nursing practice for an additional role and population focus must have a formal collaborative provider agreement for that additional credential, even if the APRN has already completed independent practice status in their original population focus.
Do Vermont PAs need a collaborating physician regardless of experience?
Yes. Unlike the APRN transition-to-practice model, Vermont’s PA framework under 26 V.S.A. § 1735a does not include an experience-based exemption. Every practicing Vermont PA must have a written practice agreement with a participating physician for the duration of their practice.
Does a Vermont PA practice agreement require chart review or co-signatures?
No. Vermont does not currently have any provisions related to chart review or chart co-signatures for PA practice agreements. The periodic joint evaluation of services described in the agreement is the relevant ongoing oversight mechanism.
Is there a limit on how many PAs a Vermont physician can collaborate with?
No. Vermont does not currently have any provisions related to the number of PAs a physician can supervise or collaborate with, giving practices more flexibility in structuring multi-PA arrangements than in states with explicit ratio caps.
