Key Takeaways
- Wisconsin no longer requires every NP to have a collaborative agreement.
Qualified APRNs can practice independently after meeting the requirements for independent practice under the new law.
- Collaboration still matters in certain situations.
Employers may require collaboration, and Wisconsin law still requires physician collaboration for certain invasive pain-management services.
- NPs should not simply discard existing agreements.
NPs should review their contracts, employment arrangements, prescribing authority, and independent-practice status before ending a physician relationship.
Do Wisconsin Nurse Practitioners Still Need Collaborative Agreements?
Wisconsin’s APRN Modernization Act marks a significant change for nurse practitioners and other advanced practice registered nurses. The law, enacted as 2025 Wisconsin Act 17, creates a separate APRN license and establishes a path for qualified APRNs to practice independently without a physician collaborative agreement. The changes took effect September 1, 2026.
For Wisconsin nurse practitioners, that raises an immediate question: Do you still need a collaborative agreement?
The answer is no, at least not in every case. But the new law does not mean that every NP immediately has unrestricted independent practice authority or that every existing physician relationship should simply be terminated.
NPs starting a practice, changing jobs, or transitioning to independent practice need to understand when collaboration is required, when it is optional, and what happens to an existing agreement.
What Does the APRN Modernization Act Change?
Historically, Wisconsin required advanced practice nurse prescribers (APNPs) to maintain a documented collaborative relationship with a physician or dentist for prescribing authority. The APRN Modernization Act replaces that framework with a separate APRN license and establishes a pathway to independent practice.
The law recognizes four APRN roles:
- Nurse practitioners
- Certified nurse midwives
- Certified registered nurse anesthetists
- Clinical nurse specialists
As of September 1, 2026, Wisconsin no longer issues new APNP credentials. Existing APNPs transition into the new APRN credentialing system, while eligible APRNs can apply for independent practice.
For nurse practitioners, the practical change is significant. A physician does not automatically have to supervise or collaborate with an NP simply because the NP is practicing in Wisconsin.
When Does a Wisconsin Nurse Practitioner Need a Collaborative Agreement?
Under the new law, an APRN who has qualified for independent practice generally does not need a physician collaborative agreement merely to practice within the APRN’s scope. However, there are exceptions:
Employer Requirements
The law allows an employer to require physician collaboration as a condition of employment.
An NP may have independent practice authority under Wisconsin law but still be required to work under a collaborative arrangement because of an employment contract or the policies of the organization where the NP works.
An NP considering a move from employment to private practice should not assume that a collaborative agreement that appears in an employment arrangement is a permanent requirement of the NP’s Wisconsin license.
Invasive Pain Management
Wisconsin law also continues to require collaboration for certain pain-management services. An APRN may provide treatment of pain syndromes through invasive techniques only while working in a collaborative relationship with a physician who has appropriate education, training, and experience in pain management, subject to the statutory exceptions.
This limitation affects NPs who provide interventional or other invasive pain-management services.
Who Qualifies for Independent APRN Practice in Wisconsin?
The new law establishes experience requirements for APRNs seeking independent practice. Generally, the APRN must:
- Complete 3,840 hours of APRN practice in the recognized role while working with a physician who was immediately available for consultation and accepted responsibility for the APRN’s actions
- Have practiced in that role for at least 24 months
The law provides additional rules on how qualifying hours can be counted, including certain hours of lawful APRN practice outside Wisconsin and practice completed in Wisconsin before September 1, 2026.
This means the transition to independent practice is not simply a matter of obtaining the new APRN license. If you want to practice independently, confirm that your education, certification, clinical experience, and practice history meet the requirements before assuming you qualify.
What Happens to an Existing Collaborative Agreement?
For many Wisconsin NPs, the biggest practical question may be what to do with an existing collaborative agreement. If you currently have a physician agreement, review it before terminating the relationship.
The agreement may contain provisions addressing:
- Termination and notice
- Employment or contractor status
- Prescribing authority
- Compensation
- Professional liability
- Restrictive covenants
- Patient transition responsibilities
- Ownership or practice relationships
This review matters most if the physician is also your employer or business partner or has another contractual relationship with your practice. Ending the collaborative relationship does not necessarily end those other obligations.
If you are reviewing an existing agreement or transitioning to independent practice, Jackson LLP can review the agreement and advise you on the legal and contractual issues involved. Contact us today to learn more.
What Should Wisconsin NPs Do Now?
If you are a Wisconsin NP affected by the APRN Modernization Act, there are several practical issues to review.
- Confirm your new APRN credential and independent-practice eligibility. The Wisconsin Department of Safety and Professional Services has established a transition process, including applications for APRN credentials and independent practice.
- Review any existing collaborative agreement. Do not assume that the agreement automatically disappears because Wisconsin law no longer requires collaboration in every circumstance.
- Review your employment or contractor agreement. An employer may continue to require collaboration even when state law permits independent practice.
- If you are planning to open your own practice, consider the broader legal structure. Address your entity, ownership, contracts, prescribing procedures, insurance, and other practice requirements together.
How Our Wisconsin Healthcare Lawyers Can Help You
Jackson LLP works with Wisconsin nurse practitioners and other advanced practice professionals on practice formation, contracts, licensing issues, and regulatory requirements. If you are transitioning to independent practice, we can review your situation and identify the agreements and legal requirements that still apply.
Our Wisconsin healthcare lawyers provide complimentary consultations. Book a time to speak with one of our attorneys for free today.
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Frequently Asked Questions About Wisconsin Nurse Practitioner Collaborative Agreements
Do Wisconsin nurse practitioners still need collaborative agreements?
Not always. Beginning September 1, 2026, qualified APRNs can practice independently without a collaborative agreement with a physician. However, employers may require collaboration, and specific services such as certain invasive pain-management treatments remain subject to collaboration requirements.
When can a Wisconsin NP practice independently?
An APRN must meet Wisconsin’s independent practice requirements, including the required clinical experience and other applicable licensing requirements. The law generally requires 3,840 hours of APRN practice while working with a physician or dentist who was immediately available for consultation and accepted responsibility for the APRN’s actions, along with a 24-month practice period.
Can an employer require a collaborative agreement?
Yes. The APRN Modernization Act permits an employer to require collaboration as a condition of employment even though Wisconsin law allows qualified APRNs to practice independently.
Can Wisconsin NPs provide pain-management services without a collaborative agreement?
Not in every circumstance. Wisconsin law requires an APRN to work in a collaborative relationship with a physician experienced in pain management when providing certain invasive treatment of pain syndromes, subject to some exceptions.
Should I terminate my existing collaborative agreement?
Not automatically. Before terminating an agreement, review its termination provisions and determine whether it is connected to your employment, compensation, prescribing authority, or another contractual relationship. Wisconsin law no longer requires collaboration in every situation, but that does not eliminate other contractual obligations.
Can a Wisconsin NP open an independent practice?
Yes. Qualified APRNs may practice independently under the new Wisconsin framework. Beyond the credential itself, NPs should also address entity formation, ownership, contracts, insurance, prescribing requirements, and other legal issues involved in operating a private practice.
