State by State Requirements
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      3. State by State Requirements

      Collaborating in Illinois

      Review the requirements to successfully collaborate as a NP or PA in Illinois

      State Regulations for Nurse Practitioners


      General

      • In which category does the state fall: NP independent practice, transition to independence, or collaboration required?
      • Transition to Independence. Independent practice authority for NPs that have completed at least 250 hours of continuing education or training and at least 4,000 hours of clinical experience after first attaining national certification.

      Delegation authority/process

      • Is an agreement required?
        •  Yes, a written collaborative agreement is required for APRNs prior to the transition to independence, except for APRNs who are privileged to practice in a hospital, hospital affiliate, or ambulatory surgical treatment center.
      • What form of agreement is required and what are the requirements for the substance of the agreement (is use of state template required?
        • The written collaborative agreement must describe the categories of care, treatment, or procedures to be provided by the NP. Additionally, the written collaborative agreement must describe the methods of communication available between the NP and collaborating physician. A collaborating physician may, but is not required to, delegate prescriptive authority to an APRN as part of a written collaborative agreement.
        • Absent an employment relationship, a written collaborative agreement may not (1) restrict the categories of patients of an advanced practice registered nurse within the scope of the APRN training and experience, (2) limit third party payors or government health programs, such as the medical assistance program or Medicare with which the APRN contracts, or (3) limit the geographic area or practice location of the APRN in IL.
      • Where must the agreement be stored?
        • No restriction, but must be made available to the state upon request.
      • Does the agreement need to be filed with the state?
        • No, but must be made available to the state upon request.
      • Are there requirements to file the agreement after the initial filing (e.g., for updates or on a specified frequency?
        • No, but see below for requirements for delegating prescriptive authority.
      • Who must sign the agreement?
        • No explicit requirement.
      • How often must the agreement be reviewed/reauthorized?
        • No restriction.
      • What are the qualifications for the collaborating provider (licensure, same scope, active practice in state, etc.)?
        • Physician, podiatrist, or dentist. Podiatry and dentist collaborators have additional requirements set forth in 225 ILCS 65/65-35.
      • What are the qualifications for the NP?
        •  See licensure requirements in 225 ILCS 65/65-5.
      • Is an alternate collaborating physician required?
        • No.

      Collaboration requirements 

      • Are there ratios/limits on the number of NPs that a collaborator may supervise or enter into collaboration agreements?
        • No restriction.
      • Is there an express requirement to review a certain number/percentage of charts?
        • No restriction.
      • Is there a requirement to meet and, if so, how often and how?
        • Remote supervision is permitted and on-site supervision is not necessarily required for any amount of time. But, the supervision will be “deemed adequate” if the physician visits on site at least once a month to provide medical direction and consultation and is available through telecommunications for consultation on medical problems, complications, or emergencies or patient referral.
      • Are there proximity requirements? (e.g., between the NP/collaborator or practice site)
        • No restriction.
      • Are there location-specific requirements? (e.g., that collaborator must go to practice site at some frequency)
        • No restriction.
      • Is remote supervision allowed/are there limitations on remote supervision?
        • No restriction.
      • Physician and NP filing requirements – outside of filing the collab agreement, must the physician and/or NP file any separate forms? (e.g., notice of delegation of prescriptive authority, notice of collaboration, notice to PDMP, etc.) NOTE: timing/frequency should be noted because the state may have requirements for initial filing and/or filing for updates, terminations, etc.
        • The collaborating physician shall file with the Department and the Prescription Monitoring Program notice of delegation of prescriptive authority and termination of such delegation, in accordance with rules of the Department. Upon receipt of this notice delegating authority to prescribe any Schedule III through V controlled substances, the licensed APRN shall be eligible to register for a mid-level practitioner controlled substance license under Section 303.05 of the Illinois Controlled Substances Act

      Filing Requirements and Prescription Guidelines

      • What are the prescription requirements? (identifying collaborators on rxs, restrictions on certain categories of drugs that may or may not be scheduled [one area of concern right now is abortion-inducing medications], etc.)
        • The collaborating physician must delegate prescribing authority to the APRN in the collaboration agreement. The delegation must be within the collaborating physician’s scope of practice and within the scope of the APRN’s training.
      • What are the requirements for controlled substance prescribing?
        • To prescribe controlled substances under, an APRN must obtain a mid-level practitioner controlled substance license. Medication orders shall be reviewed periodically by the collaborating physician.
      • A collaborating physician may, but is not required to, delegate authority to an advanced practice registered nurse to prescribe any Schedule II controlled substances, if all of the following conditions apply:
        • (1) Specific Schedule II controlled substances by oral dosage or topical or transdermal application may be delegated, provided that the delegated Schedule II controlled substances are routinely prescribed by the collaborating physician. This delegation must identify the specific Schedule II controlled substances by either brand name or generic name. Schedule II controlled substances to be delivered by injection or other route of administration may not be delegated.
        • (2) Any delegation must be controlled substances that the collaborating physician prescribes.
        • (3) Any prescription must be limited to no more than a 30-day supply, with any continuation authorized only after prior approval of the collaborating physician.
        • (4) The APRN must discuss the condition of any patients for whom a controlled substance is prescribed monthly with the delegating physician.
        • (5) The APRN meets the education requirements of Section 303.05 of the Illinois Controlled Substances Act.

      Sources for Reference

      State Regulations for Physician Assistants

      General:

      • A physician shall not be liable for the acts or omissions of a PA solely on the basis of having signed a supervision agreement or guidelines or a collaborative agreement, an order, a standing medical order, a standing delegation order, or other order or guideline authorizing PA to perform acts, unless the physician has reason to believe the PA lacked the competency to perform the act or acts or commits willful and wanton misconduct. However, the collaborating physician shall maintain the final responsibility for the case of the patient and performance of the PA. 
      • Whenever a PA is employed by a collaborating physician who is a member of a professional corporation or partnership or whenever the collaborating physician or PA is an employee of a professional corporation or partnership, the collaborating physician shall maintain the responsibility for the PA and for the care and treatment of the persons attended by the PA. Responsibility for the PA cannot be transferred to such corporation or partnership.
      • Delegated procedures and tasks performed by the PA shall be within the current scope of practice of the collaborating physician with whom PA is working at the time.
      • Delegation authority/process:
        • Is an agreement required?
          • Yes. The delegated tasks or duties shall be specific to the practice setting and shall be implemented and reviewed under a written collaborative agreement established by the physician or physician/PA team.
        • What form of agreement is required and what are the requirements for the substance of the agreement (is use of state template required?)
          • Physician Assistant Notice of Written Collaboration can be found here.
          • Notice of Delegated Authority for Prescription Drugs (Non-CS) can be found here.
          • Notice of Delegated Authority for Controlled Substances can be found here.
          • All forms are periodically updated. To make sure the most up-to-date forms are being used, visit this site here.
        • Where must the agreement be stored?
          • A copy of the signed, written collaborative agreement must be available to the Department upon request from both the PA and the collaborating physician.
          • The physician/PA team shall establish a written collaborative agreement that is individual to the PA in the practice setting and keep that agreement current and available in the collaborating physician's office or location where the physician assistant is practicing.
        • Does the agreement need to be filed with the state?
          • Yes. Prior to a PA performing any medical procedure or other task delegated by a collaborating physician, the collaborating physician must file with the Division notice of employment or collaboration.
          • The collaborating physician shall file with the Department notice of employment, discharge, or collaboration with a PA within 60 days of employment, discharge, or assumption of collaboration with a PA. Nothing prevents a PA from beginning his or her employment before the notice of employment or collaboration has been filed.
        • Are there requirements to file the agreement after the initial filing (e.g., for updates or on a specified frequency)
          • Yes. The collaborating physician shall file with the Department notice of employment, discharge, or collaboration with a PA within 60 days of employment, discharge, or assumption of collaboration with a PA. 
            • Any PA required to enter into a written collaborative agreement with a collaborating physician is authorized to continue to practice for up to 90 days after the termination of a written collaborative agreement, provided the PA seeks any necessary collaboration at a local hospital and refers patients who require services beyond the training and experience of the PA to a physician or other health care provider.
          • If the written collaborative agreement or employment is terminated, the collaborating physician must, within 10 days of termination, complete and submit to the Division a Notice of Termination of Collaboration form. Notice of Termination of Collaboration and/or Delegated Authority can be found here.
        • Who must sign the agreement?
          • PA 
          • Collaborating Physician
        • How often must the agreement be reviewed/reauthorized?
          • Not specified.
        • What are the qualifications for the supervising physician (licensure, same scope, active practice in state, etc.)?
          • The supervising physician must be licensed under the Illinois Medical Practice Act. 
          • A PA is only authorized to practice within the current scope of practice of the collaborating physician and is further limited by his/her education, training and experience. The collaborating physician must be engaged in clinical practice, or in clinical practice in public health or other community health facilities.
          • A PA may be employed by a practice group or other entity employing multiple physicians at one or more locations. In that case, one of the physicians practicing at a location shall be designated the collaborating physician. The other physicians with that practice group or other entity who practice in the same general type of practice or specialty as the collaborating physician may collaborate with the PA with respect to their patients.
          • Methods of communication shall be available for consultation with the collaborating physician in person or by telecommunications or electronic communications as set forth in the written collaborative agreement.
        • Is an alternate supervising physician required?
          • If the PA has a written collaborative agreement with more than one physician, a separate notice of prescriptive authority shall be submitted by each collaborating physician.
          • The PA shall only work under the direction of the current collaborating physicians and may undertake patient care responsibilities only for the patients of the collaborating physicians.
      • Supervision requirements
        • Are there ratios/limits on the number of PAs that a supervising physician may supervise? 
          • A collaborating physician shall determine the number of PAs to collaborate with, provided the physician is able to provide adequate collaboration as outlined in the written collaborative agreement and consideration is given to the nature of the physician’s practice, complexity of the patient population, and the experience of each PA. 
          • A collaborating physician may collaborate with a maximum of 7 full-time equivalent PA, except in a hospital, hospital affiliate, or ambulatory surgical treatment center as set forth by Section 7.7 of the Physician Assistant Practice Act (there is also an exception for services provided in a federal primary care health professional shortage area with a Health Professional Shortage Area score greater than or equal to 12). “Full-time equivalent” means the equivalent of 40 hours per week per individual. 
          • A PA shall be able to hold more than one professional position. A collaborating physician shall file a notice of collaboration of each PA according to the rules of the Department.
          • A PA shall inform each collaborating physician of all written collaborative agreements he or she has signed and provide a copy of these to any collaborating physician upon request.
          • A PA shall not be allowed to personally bill patients or in any way charge for services. The employer of a PA may charge for services rendered by the PA. All claims for services rendered by the PA shall be submitted using the PA’s national provider identification number as the rendering provider whenever appropriate. Payment for services rendered by a PA shall be made to his or her employer if the payor would have made payment had the services been provided by a physician licensed to provide medicine in all of its branches.
        • Is there an express requirement to review a certain number/percentage of charts?
          • The collaborating physician shall have access to the medical records of all patients attended to by the PA.
        • Is there a requirement to meet and, if so, how often and how? 
          • The physician must provide consultation at least once a month.
          • The collaborating physician must direct and review the work, records and practice of the PA at least once a month to ensure that appropriate directions are given and understood and that appropriate treatment is being rendered.
        • Are there proximity requirements? (e.g., between the PA/physician or practice site)
          •  Collaboration with the PA shall not be construed to necessarily require the personal presence of the collaborating physician at all times at the place where services are rendered, as long as there is communication available for consultation by radio, telephone or telecommunications within established guidelines as determined by the physician/PA team.
        • Are there location-specific requirements? (e.g., that physician must go to practice site at some frequency)
          • The relationship under a written collaborative does require the personal presence of a physician at the place where services are rendered. Methods of communication shall be available for consultation with the collaborating physician in person or by telecommunications or electronic communications as set forth in the written collaborative agreement. 
        • Is remote supervision allowed/are there limitations on remote supervision?
          • In the event that the collaborating physician is not present in the same facility as the PA, the collaborating physician should be available for consultation by telecommunication or electronic communication as set forth in their collaborative agreement.
        • Are there patient notice requirements?
          • No PA may use the title of doctor, physician, or associate with his or her name or any other term that would indicate to other persons that he or she is qualified to engage in the general practice of medicine. A PA shall verbally identify himself or herself as a PA, including specialty certification, to each patient. A PA shall wear on his or her person a visible identification indicating that he or she is certified as a physician assistant while acting in the course of his or her duties.
        • Physician and PA filing requirements – outside of filing the delegation agreement, must the physician and/or PA file any separate forms? 
          •  Forms listed above.
        • What are the prescription requirements? (identifying physician on rxs, restrictions on certain categorizes of drugs that may or may not be scheduled [one area of concern right now is abortion-inducing medications], etc.)
          •  A collaborating physician may, but is not required to, delegate prescriptive authority to PA as part of a written collaborative agreement. This authority may, but is not required to, include prescription of, selection of, orders for, administration of, storage of, acceptance of samples of, and dispensing medical devices, over the counter medications, legend drugs, medical gases, and controlled substances categorized as Schedule II through V controlled substances, as defined in Article II of the Illinois Controlled Substances Act, and other preparations, including, but not limited to, botanical and herbal remedies. The collaborating physician must have a valid, current Illinois controlled substance license and federal registration with the Drug Enforcement Administration to delegate the authority to prescribe controlled substances.
        • What are the requirements for controlled substance prescribing?
          • To prescribe Schedule II, III, IV, or V controlled substances, a PA must obtain a mid-level practitioner controlled substances license. Medication orders issued by a PA shall be reviewed periodically by the collaborating physician.
          • The collaborating physician shall file with the Department notice of delegation of prescriptive authority to a PA and termination of delegation, specifying the authority delegated or terminated. Upon receipt of this notice delegating authority to prescribe controlled substances, the PA shall be eligible to register for a mid-level practitioner controlled substances license under Section 303.05 of the Illinois Controlled Substances Act. 
          • A collaborating physician may, but is not required to, delegate authority to a PA to prescribe Schedule II controlled substances, if all of the following conditions apply:
            • (A) Specific Schedule II controlled substances by oral dosage or topical or transdermal application may be delegated, provided that the delegated Schedule II controlled substances are routinely prescribed by the collaborating physician. This delegation must identify the specific Schedule II controlled substances by either brand name or generic name. Schedule II controlled substances to be delivered by injection or other route of administration may not be delegated.
            • (B) Any prescription must be limited to no more than a 30-day supply, with any continuation authorized only after prior approval of the collaborating physician.
            • (C) The PA must discuss the condition of any patients for whom a controlled substance is prescribed monthly with the collaborating physician.
            • (D) The PA meets the education requirements of Section 303.05 of the Illinois Controlled Substances Act.
          • A collaborating physician and PA shall have written guidelines that govern the PA delegated prescriptive authority. The written guidelines shall include a statement indicating that the collaborating physician has delegated prescriptive authority for legend drugs and/or any schedule of controlled substances. The delegation must be appropriate to the physician's practice and within the scope of the PA's training. The written guidelines shall be signed by both the physician and the PA. The PA's state-controlled substance license number and the Drug Enforcement Administration (DEA) registration number shall be maintained at each location where the PA practices. A copy of the written prescriptive guidelines shall be made immediately available upon request.
          • A PA may only prescribe or dispense prescriptions or orders for drugs and medical supplies within the scope of practice of the collaborating physician.
          • Medication orders issued by a PA shall be reviewed periodically by the collaborating physician.

      Sources for Reference

      • 225 ILCS 60/54.2
      • 225 ILCS 60/54.5
      • 225 ILCS 95/4
      • 225 ILCS 95/5.3
      • 225 ILCS 95/5.5
      • 225 ILCS 95/6
      • 225 ILCS 95/7
      • 225 ILCS 95/7.5
      • 225 ILCS 95/7.6
      • 225 ILCS 95/10
      • 720 ILCS 570/303.05
      • 50 Ill. Adm. Code 1350.20
      • 50 Ill. Adm. Code 1350.40
      • 50 Ill. Adm. Code 1350.55
      • 50 Ill. Adm. Code 1350.60
      • 50 Ill. Adm. Code 1350.80
      • 50 Ill. Adm. Code 1350.90
      • 50 Ill. Adm. Code 1350.100
      • 50 Ill. Adm. Code 1350.110
      • 50 Ill. Adm. Code 1350.112
      • 50 Ill. Adm. Code 1350.116