Collaborating in Tennessee

Learn more about the requirements to practice and collaborate in Tennessee!

What Is the Practice Environment for NPs in Tennessee

Is a collaboration with a physician required?

Yes, a collaboration is required. Tennessee is classified as a Restricted Practice Authority State.

Delegation Authority and Process

Is an agreement required?

Yes, a written protocol.

What form of agreement is required and what are the requirements for the substance of the agreement?

The written protocol must:

• Be dated and signed by the physician and NP;
• Outline the applicable standard of care;
• List all delegated drugs by formulary;
• Cover the applicable standard of care;
• Specify the classes of drugs that may be prescribed by the NP; and
• Be specific to the population seen.
• Additionally, the supervising physician shall develop clinical guidelines in collaboration with the NP to include a method for documenting consultation and referral.

Where must the agreement be stored?

Copies of the protocol must be maintained at each practice site and made available upon request.

Does the agreement need to be filed with the state?

There is no filing requirement.

Are there requirements to file the agreement after the initial filing (e.g., for updates or on a specified frequency)?

No requirement.

Who must sign the agreement?

The law does not specifically say, but implies it must be signed and dated by the NP and supervising physician.

How often must the agreement be reviewed/reauthorized?

The written protocol must be reviewed and updated at least once every two years.

What are the qualifications for the collaborating provider (licensure, same scope, active practice in state, etc.)?

To qualify as a supervising physician, the physician must be licensed in Tennessee and “actively practicing.” There is no explicit requirement that the supervising physician be actively practicing within TN, but it is possible the board would deem it a requirement.

A physician should have “experience and/or expertise in the same area of medicine as the PA/APRN” (which encompasses “the range of services routinely provided in the course of [the supervising physician’s] medical practice” and “may also include services not routinely provided, but regarding which the physician has specific, up-to date, reliable knowledge acquired during his or her medical  training”).

What are the qualifications for the NP?

See application requirements here. 

Is an alternate collaborating physician required?

There is no requirement.

Collaboration Requirements

Are there ratios/limits on the number of NPs that a collaborator may supervise or enter into collaboration agreements?

There is no prescribed number of PA/APRN supervisees. The number of PAs/APRNs a physician may supervise should be determined by the physician at the practice level, consistent with good medical practice.

Is there an express requirement to review a certain number/percentage of charts?

Yes. Once every ten (10) business days, the supervising physician must personally review “historical, physical and therapeutic data” and certify by signature on any patient within thirty (30) days when: 

• Medically indicated;
• Requested by the patient;
• Prescriptions written by the NP fall outside the protocol; 
• Prescriptions are written by a NP who possesses a temporary certificate of fitness; or
• A controlled drug has been prescribed. 

In any event, a supervising physician must personally review at least twenty percent (20%) of charts monitored or written by the NP every thirty (30) days.

Is there a requirement to meet and, if so, how often and how?

The supervising physician (or a proper, designated substitute supervisor) is required to visit any “remote site” where the NP is practicing once every thirty (30) days.

Are there proximity requirements?

There are no proximity requirements.

Are there location-specific requirements (e.g., that collaborator must go to practice site at some frequency)?

The NP “may arrange for up to ten (10) of the required annual remote site visits by a collaborating physician by HIPAA-compliant electronic means rather than at the site of the clinic. All other of the required site visits by a collaborating physician to a remote site must take place in person at the site of the clinic[.]”

Is remote supervision allowed/are there limitations on remote supervision?

Supervision does not require “the continuous and constant presence of the supervising physician” but the supervising physician (or a proper, designated substitute supervisor) “must be available for consultation at all times.”

Physician and NP Filing Requirements

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.)? 

The NP must file notice with the Nursing Board, including a written formulary listing the categories of drugs to be prescribed or issued by the NP and identifying the supervising physician(s) and practice site(s). The NP is responsible for updating this information.

Prescription Requirements and Controlled Substance Prescribing

What are the prescription requirements?

Every prescription issued by a NP must be signed by the NP and written on a preprinted prescription pad bearing the name, address, and phone number of the collaborating physician and the NP. If the pad contains the names of more than one physician, the NP shall indicate with a check or circle which is the primary collaborating physician.

What are the requirements for controlled substance prescribing?

An NP shall not prescribe Schedules II, III, and IV controlled substances unless such prescription is specifically authorized by the formulary or expressly approved after consultation with the collaborating physician before the initial issuance of the prescription or dispensing of the medication.

An NP who had been issued a certificate of fitness may only prescribe or issue a Schedule II or III opioid listed on the formulary for a maximum of a non-refillable, thirty-day course of treatment unless specifically approved after consultation with the collaborating physician before the initial issuance of the prescription or dispensing of the medication. This shall not apply to prescriptions issued in a hospital, a nursing home licensed under title 68, or inpatient facilities licensed under title 33.

Each of the NP and supervising physician must have a DEA registration and be registered with the Controlled Substance Monitoring Database Program.

Sources

Tenn. Code Ann. § 63-7-123

Tenn. Comp. R. & Regs.  0880-06-.01

Tenn. Comp. R. & Regs.  0880-06-.02

FAQ: Physician Supervision of PAs and APNs, Tenn. Bd. of Med.  Examiners (Oct. 2016)