Virginia collaborating physician requirements apply to a market in active transition. Virginia is a transitional practice state for nurse practitioners, meaning physician collaboration is required for NPs who have not yet accumulated sufficient clinical experience to qualify for autonomous practice. NPs with fewer than three years of full-time clinical experience must practice under a written or electronic practice agreement with a patient care team physician. NPs who meet the three-year threshold may apply for the autonomous practice designation, removing the written agreement requirement.
For physicians entering collaboration roles in Virginia, the framework is substantive and governed by Virginia Code § 54.1-2957 and § 54.1-2957.01 and regulations at 18 VAC 90-40. Understanding the practice agreement requirements, the physician ratio limits, the prescriptive authority scope, and what happens when a collaboration ends unexpectedly is essential before signing anything. This guide covers every requirement a physician needs to understand in 2026.
Virginia Collaborating Physician Overview: Where Virginia Stands
Virginia uses a patient care team model for NP-physician collaboration. The physician is called the patient care team physician, and the NP-physician relationship is governed jointly by the Virginia Board of Medicine and the Virginia Board of Nursing.
Governing Bodies
Two regulatory bodies govern these arrangements:
- Virginia Board of Nursing: Governs NP licensure, practice agreement requirements, the autonomous practice designation, and APRN prescriptive authority under Virginia Code § 54.1-2957.
- Virginia Board of Medicine: Governs physician licensure, prescriptive authority delegation, and jointly enforces practice agreement standards with the Board of Nursing under Virginia Code § 54.1-2957.01.
Both boards must jointly approve certain regulatory matters and both retain independent disciplinary authority over their respective licensees.
Practice Authority Classification
Virginia places NPs in a transitional practice category. Physician collaboration is required during the early career period, with a defined pathway to autonomous practice once qualifying experience is accumulated. As of July 1, 2024, under HB 971 signed by Governor Youngkin, the experience threshold to apply for autonomous practice was reduced from five years to three years of full-time clinical experience, defined as 5,400 clinical hours. NPs who applied before July 1, 2024 were still required to show five years of experience.
The Practice Agreement: Virginia’s Core Compliance Document
Virginia uses the term practice agreement, also referred to as a collaborative practice agreement. Under Virginia Code § 54.1-2957, an NP who has not completed the qualifying experience for autonomous practice must practice under a written or electronic practice agreement with a patient care team physician.
The practice agreement does not need to be filed with either the Board of Nursing or the Board of Medicine. The NP must maintain the agreement and have it available for inspection. Both the physician and the NP should retain copies of all executed agreements.
No Geographic Proximity Requirement
Virginia does not impose a geographic proximity requirement on patient care team physicians. Collaboration and consultation may be provided through telemedicine. A physician in Northern Virginia can serve as a patient care team physician for an NP clinic in Southwest Virginia. The absence of a proximity rule makes Virginia one of the more flexible reduced-practice states for remote collaboration.
Practice Agreement vs. Autonomous Practice
An NP with the autonomous practice designation is not required to have a written practice agreement. However, autonomous NPs are still required to consult and collaborate with other health care providers as appropriate and to maintain a plan for referral of complex cases and emergencies. The physician’s role with an autonomous NP is consultative and informal rather than governed by a formal written agreement.
What Must Be in a Virginia Practice Agreement
Virginia Code § 54.1-2957 and 18 VAC 90-40 specify the required elements of a valid practice agreement. The agreement must address all of the following:
1. Identification of the Parties
The practice agreement must identify the NP and the patient care team physician by name. The physician must be licensed in Virginia and qualified to practice in a specialty relevant to the NP’s patient population.
2. Patient Population and Practice Area
The agreement must describe the patient population the NP will serve and the practice area in which the NP is certified and licensed. This scope description must align with the NP’s certification category.
3. Prescriptive Authority Scope
The agreement must specify the drugs and devices the NP is authorized to prescribe, including controlled substances if applicable. Prescribing must occur within the terms of the agreement and within the NP’s certification category.
4. Patient Record Review
The practice agreement should provide for the periodic review of health records by the patient care team physician. This review may include site visits but site visits are not expressly required by regulation. The frequency of review is determined by the parties and documented in the agreement.
5. Consultation and Referral Process
The agreement must describe how the NP will obtain consultation from the physician when clinical situations require it, and how patients will be referred when care exceeds the NP’s scope.
6. Emergency and Absence Coverage
The agreement must address how patient care is managed in the event of an emergency or when either the NP or the physician is unavailable.
Optional but Recommended Provisions
While not required, Virginia practitioners frequently include the following in practice agreements:
- A designated backup physician for consultation when the primary physician cannot be reached
- Specific authorizations for tasks that might otherwise be considered outside the NP’s standard scope, such as signing DNR orders or writing prescriptions for specific controlled substances
- Explicit exclusions identifying tasks the NP will not perform under the agreement
Physician Eligibility and the Patient Care Team Model
A Virginia patient care team physician must hold a current, active, and unrestricted license to practice medicine in Virginia. The physician must be qualified to practice in a specialty relevant to the NP’s patient population and practice area.
Virginia does not publish a mandatory specialty comparability standard identical to Georgia’s, but the patient care team concept implies that the physician and NP are working within a shared or compatible clinical framework. A physician whose practice has no clinical overlap with the NP’s patient population will struggle to provide meaningful oversight or consultation.
Employment Restrictions
Virginia does not generally prohibit a physician from being employed by an NP they collaborate with, unlike Georgia. However, both parties should structure compensation for the collaboration as a flat fee for services rendered rather than a percentage of practice revenue to avoid fee-splitting concerns under Virginia law and professional conduct standards.
The Physician-to-NP Ratio in Virginia
Virginia imposes a hard cap on the number of NPs a single patient care team physician may collaborate with at any one time under 18 VAC 90-40-90(D) and Virginia Code § 54.1-2957.01.
Standard Settings
A physician shall not serve as a patient care team physician to more than six advanced practice registered nurses with prescriptive authority at any one time.
Psychiatric-Mental Health Exception
A physician may serve as a patient care team physician on a patient care team with up to 10 nurse practitioners licensed in the category of psychiatric-mental health nurse practitioner. This expanded limit reflects the significant demand for psychiatric NP collaboration and the shortage of psychiatric physicians willing to serve in this role.
What Counts Toward the Ratio
The ratio applies to NPs with prescriptive authority. NPs without prescriptive authority, or NPs who have already obtained the autonomous practice designation, are not counted toward the six-NP cap.
Prescriptive Authority and Controlled Substances in Virginia
Under Virginia Code § 54.1-2957.01, NPs practicing under a written practice agreement may prescribe Schedule II through Schedule VI controlled substances within the scope of the practice agreement and the NP’s certification category.
DEA Registration
NPs prescribing controlled substances must hold a current DEA registration. Prescribing must occur within the terms of the practice agreement and consistent with the NP’s licensure category.
No Schedule II Prohibition
Virginia does not impose a blanket prohibition on Schedule II prescribing for NPs practicing under a physician agreement. This distinguishes Virginia significantly from states like Georgia and Missouri, which restrict or prohibit APRN Schedule II prescribing entirely. Virginia NPs with prescriptive authority can prescribe the full range of Schedule II through VI controlled substances within their practice agreement scope.
Certified Nurse Midwife Prescribing
CNMs in Virginia who hold a license for prescriptive authority may prescribe Schedule II through VI controlled substances. A CNM who has completed 1,000 hours of practice as a CNM may practice without a practice agreement. If still practicing under a practice agreement, prescribing takes place within the terms of that agreement.
The Autonomous Practice Pathway: What It Means for Physicians
Virginia’s autonomous practice pathway creates a dynamic that affects how physicians structure and plan their collaboration arrangements.
The Three-Year Threshold (Effective July 1, 2024)
Under HB 971 and Virginia Code § 54.1-2957, an NP who has completed three years of full-time clinical experience (5,400 hours, based on a minimum 36-hour work week per year) may apply to the Virginia Board of Nursing for the autonomous practice designation. Qualifying experience means postgraduate delivery of health care directly to patients pursuant to a practice agreement with a patient care team physician.
What the Application Requires
To apply for autonomous practice, the NP must obtain an attestation from the patient care team physician with whom they practiced during the qualifying period. The attestation confirms that:
- The physician served as a patient care team physician under a qualifying practice agreement
- The physician routinely practiced with a patient population in a practice area included within the NP’s certification category during the practice period
- The NP practiced for the equivalent of three years in that arrangement
An NP who cannot obtain the required physician attestation due to the physician’s death, disability, retirement, or relocation may provide alternative evidence such as employment records, Medicare or Medicaid billing records, or other official documentation of qualifying practice.
Implications for Collaborating Physicians
Physicians collaborating with NPs in Virginia should understand that their attestation may be requested when the NP applies for autonomous practice. Maintaining thorough documentation of the collaboration from the beginning ensures the physician can provide an accurate attestation when the time comes. An undocumented or loosely managed collaboration makes the attestation process more difficult for both parties.
The 60-Day Continuation Provision
Virginia Code § 54.1-2957(G) provides a specific protection for NPs when a patient care team physician unexpectedly becomes unable to serve.
When the 60-Day Window Applies
If a physician who is serving as a patient care team physician dies, becomes disabled, retires from active practice, surrenders their license, has it suspended or revoked, or relocates their practice such that they are no longer able to serve, and the NP is unable to enter into a new practice agreement with another physician, the NP may continue to practice for an initial period of up to 60 days after notifying the Boards of Medicine and Nursing.
During this 60-day period, the NP may continue to treat patients but may only prescribe drugs previously authorized by the practice agreement with the departing physician.
Extension Beyond 60 Days
Under HB 971, at the conclusion of the first 60-day period, the Boards may grant permission for the NP to continue practicing for an additional period under the management and leadership of a qualified NP, defined as an NP who holds the autonomous practice designation in Virginia, has held it for at least three years, practices in the same NP category, and routinely practices with the same patient population. The NP must provide evidence of continued efforts to secure a replacement patient care team physician.
What This Means for Physicians
The 60-day provision exists to protect the NP and their patients when a physician can no longer serve. It also creates a compliance obligation for physicians who end arrangements: the manner in which the physician terminates the arrangement affects how much time the NP has to find a replacement. Physicians who give advance notice rather than terminating abruptly give the NP the best opportunity to secure a new agreement without a practice gap.
Remote Collaboration and Telemedicine
Virginia explicitly permits collaboration and consultation between the NP and the patient care team physician through telemedicine. This means:
- The physician does not need to be physically present at the NP’s practice location
- Consultations and chart reviews can be conducted remotely
- The practice agreement may authorize telemedicine-based oversight without requiring in-person site visits
Virginia’s telemedicine flexibility, combined with the absence of a geographic proximity requirement, makes it one of the more accessible states for physicians seeking remote collaboration roles. A physician practicing in Virginia or in an adjacent state can serve as a patient care team physician for an NP clinic anywhere in Virginia without any proximity restriction.
Common Compliance Mistakes Virginia Collaborating Physicians Make
Most Virginia practice agreement compliance problems involve documentation gaps, inadequate agreement terms, and failure to prepare for the autonomous practice attestation.
- Practice agreement does not specify controlled substance scope. Virginia NPs can prescribe Schedule II through VI controlled substances, but the practice agreement must define what is authorized. An agreement that is silent on controlled substances creates ambiguity about what the NP is actually authorized to prescribe.
- No backup physician identified. While not required, failing to identify a backup physician for consultation when the primary physician is unavailable creates a gap in the NP’s ability to obtain consultation during practice. This gap can become a compliance issue during an investigation.
- Ratio exceeded. A physician may not serve as patient care team physician for more than six NPs with prescriptive authority simultaneously, or more than 10 psychiatric-mental health NPs. Physicians collaborating with multiple Virginia clinics need to count all active NPs toward the applicable cap.
- Attestation not documented throughout the collaboration. When the NP applies for autonomous practice, they need a physician attestation confirming the qualifying practice period. Physicians who did not maintain records of the collaboration’s scope, patient population, and duration will find it difficult to provide an accurate attestation.
- Agreement not updated when the NP’s practice area changes. If the NP expands into a new service area or adds a new patient population, the practice agreement must be updated to reflect the current scope. Operating under an agreement that no longer accurately describes the NP’s practice creates a compliance gap.
- No process for the physician to become unavailable. The 60-day continuation provision is triggered when the physician unexpectedly cannot serve. Physicians who plan to end an arrangement should give the NP as much advance notice as possible and document the transition process to support the NP’s ability to find a replacement.
Virginia Collaborating Physician Requirements: Quick Reference
Physician Eligibility
- Active, unrestricted Virginia MD or DO license
- Must be qualified to practice in a specialty relevant to the NP’s patient population
- Physician called a patient care team physician under Virginia law
Core Compliance Document
- Written or electronic practice agreement under Virginia Code § 54.1-2957
- Must address: party identification, patient population, prescriptive authority scope, record review, consultation process, emergency coverage
- Not filed with state boards; maintained by both parties
Physician-to-NP Ratio
- Maximum of 6 NPs with prescriptive authority per physician
- Maximum of 10 psychiatric-mental health NPs per physician
Prescriptive Authority
- NPs may prescribe Schedule II through VI controlled substances within the practice agreement
- No blanket Schedule II prohibition
- DEA registration required for controlled substance prescribing
Autonomous Practice Pathway
- NPs with 3 years (5,400 hours) of full-time clinical experience may apply for autonomous practice designation (effective July 1, 2024)
- Application requires physician attestation confirming the qualifying practice period
- Autonomous NPs no longer require a written practice agreement
60-Day Continuation Provision
- NP may continue practicing for up to 60 days after physician unexpectedly becomes unable to serve
- NP must notify Boards of Medicine and Nursing immediately
- Extension beyond 60 days possible under Board supervision
Geographic Requirement
- None; telemedicine collaboration is explicitly permitted
Record Retention
- Both parties should retain copies of all executed agreements
- Documentation of the collaboration supports the NP’s eventual autonomous practice attestation
Clinics Also Need to Understand Virginia Collaboration Requirements
While this guide primarily covers the responsibilities and compliance requirements placed on collaborating physicians in Virginia, these regulations directly affect NP-owned clinics, medspas, and healthcare practices that depend on physician collaboration to operate. In many cases, clinic owners researching Virginia collaboration rules are also trying to understand how to find a qualified patient care team physician whose background aligns with the NP’s practice area, who fits within the six-NP ratio limit, and who is prepared to provide the attestation the NP will eventually need for autonomous practice.
Need Help Finding a Virginia 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, familiar with Virginia’s practice agreement requirements, and who understands the autonomous practice attestation process that sits at the end of the collaboration period. Whether you are launching a new NP-operated clinic, replacing a physician whose situation has changed, or navigating the 60-day continuation window and need a new patient care team physician quickly, having the right physician relationship in place is essential.
If your clinic is actively looking for a Virginia collaborating physician, our team can match you with a qualified physician, often within 24 to 48 hours. We work with clinics across Virginia to simplify the physician matching process while supporting onboarding, agreement drafting, and long-term collaboration needs.
Final Thoughts
Virginia collaborating physician requirements reflect a state that is actively evolving toward greater NP practice authority while maintaining a structured transition period for early-career practitioners. The practice agreement is the legal instrument governing the NP’s prescribing scope, consultation process, and clinical authority during that transition period. The physician’s role is both a compliance obligation and a direct contributor to the NP’s ability to eventually qualify for autonomous practice.
For physicians entering the Virginia market, the most important steps are drafting a practice agreement that accurately reflects the NP’s patient population and prescribing scope, staying within the six-NP ratio, and maintaining thorough documentation throughout the collaboration to support the attestation process when the time comes.
Build a Compliant Virginia Collaboration With Collaborating Physician
Are you looking for a collaborating physician role in Virginia? If you are a licensed Virginia physician interested in a structured, compliant practice 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 Virginia and 50-plus other states. Every arrangement is built to meet state-specific requirements, including Virginia’s practice agreement mandates under § 54.1-2957, the six-NP patient care team ratio, Schedule II through VI prescriptive authority scope, and the documentation standards that support the NP’s eventual autonomous practice attestation. 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 Virginia clinics with qualified, vetted patient care team physicians who are ready to enter into properly drafted practice agreements. Whether you are launching a new NP-operated clinic, managing the 60-day continuation window after losing a physician, or simply looking to find a physician whose specialty aligns with your NP’s practice area, 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. Virginia healthcare regulations change frequently. Always verify current requirements directly with the Virginia Board of Nursing, the Virginia Board of Medicine, and a qualified healthcare attorney before making any practice decisions.
Frequently Asked Questions
Does a Virginia patient care team physician need to be physically present at the NP’s clinic?
No. Virginia does not impose a geographic proximity requirement on patient care team physicians. Collaboration and consultation may occur through telemedicine. The physician does not need to share office space or be co-located with the NP. The practice agreement must address how consultation will occur and how patient records will be reviewed, but those obligations can be met remotely.
What experience does a Virginia NP need before practicing without a physician agreement?
As of July 1, 2024, an NP who has completed three years of full-time clinical experience, defined as 5,400 hours based on a minimum 36-hour work week per year, may apply to the Virginia Board of Nursing for the autonomous practice designation. The application requires an attestation from the patient care team physician confirming the qualifying practice period.
How many NPs can one Virginia physician collaborate with?
A patient care team physician may not serve as physician for more than six NPs with prescriptive authority at any one time. The exception applies to psychiatric-mental health NPs, where a physician may serve as patient care team physician for up to ten NPs licensed in that category simultaneously.
Can a Virginia NP prescribe Schedule II controlled substances?
Yes. Virginia does not impose a blanket prohibition on Schedule II prescribing for NPs practicing under a written practice agreement. NPs may prescribe Schedule II through Schedule VI controlled substances within the terms of the practice agreement and their certification category, provided they hold a current DEA registration.
What happens if a Virginia NP loses their patient care team physician unexpectedly?
If the physician dies, becomes disabled, retires, surrenders their license, or relocates, the NP may continue to practice for up to 60 days after notifying the Boards of Medicine and Nursing. During that period, the NP may only prescribe drugs previously authorized under the prior practice agreement. If a replacement physician cannot be found within 60 days, the Boards may grant an extension under certain conditions, including the NP being managed by a qualified autonomous NP.
Does the Virginia practice agreement need to be filed with any state board?
No. The practice agreement does not need to be filed with the Virginia Board of Nursing or the Virginia Board of Medicine. Both the NP and the physician should maintain copies of all executed agreements. The NP should also retain documentation that supports the physician’s eventual attestation for autonomous practice, including records of the collaboration’s patient population, scope, and duration.
