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New York, Kansas, Massachusetts, and Delaware Become the latest States to Adopt Full Practice Authority for Nurse Practitioners

Client Alert

While the COVID-19 pandemic certainly created many obstacles and hardships, it also created many opportunities to try doing things differently. This can be seen in the instant rise of remote work opportunities, telehealth visits, and virtual meetings. Many States took the challenges of the pandemic and turned them into an opportunity to adjust the regulations governing licensed professionals, including for advanced practice registered nurses (APRNs). 

On April 15, 2022, Kansas became the latest state to remove practice restrictions on nurse practitioners and allow them to practice completely independent of any regulatorily mandated contractual relationship with a physician. This was very shortly after similar changes were made in New York, Massachusetts, and Delaware. In total, 26 States, the District of Columbia, and two U.S. territories (Guam and Northern Mariana Islands) now permit nurse practitioners to practice without any mandated collaborative agreement or supervision. Many other States, including Ohio, are currently evaluating legislation to implement full practice authority for APRNs. A map illustrating the current position of all U.S. States and territories regarding full practice authority can be found here.

It should be noted that each full practice authority State is different with regards to the requirements to practice independently. For example, some States require a transition to practice period where the APRN practices under supervision or regulatory collaboration for a minimum period of time before being licensed to practice independently.

The trend towards adopting full practice authority for APRNs will have a direct impact on the number of patient care roles that will be filled by APRNs. Over the course of seven years (as reported in 2020), the number of nurse practitioners in the U.S. more than doubled. Additionally, the U.S. Department of Labor expects the number of jobs held by nurse practitioners, CRNAs, and certified nurse midwives to increase 45% between 2020 and 2030.

If you have questions about APRN practice rules or starting an APRN-driven business, please don’t hesitate to contact Jeana Singleton by email at: jmsingleton@bmdllc.com, or by phone at: (330) 253-2001 or another member of the Health Law Department at Brennan, Manna & Diamond.


CMS Requires Providers to Use an Updated Advance Beneficiary Notice (ABN) Form by May 12, 2026

CMS has released an updated Advance Beneficiary Notice of Noncoverage (ABN), Form CMS-R-131, that all providers and suppliers must begin using by May 12, 2026. The revised form includes clearer language and formatting updates intended to improve patient understanding and compliance.

CMS and Ohio Ramp Up Fraud Enforcement in Home Health and Hospice

CMS and Ohio have launched sweeping new fraud prevention initiatives targeting home health and hospice providers, signaling a period of heightened scrutiny for enrollment, billing, documentation, and EVV compliance. While aimed at combating fraud, these measures also create significant operational and due process risks for compliant agencies, making proactive compliance programs, auditing, and governance more important than ever.

MYTH BUSTER: Can a New Chiropractor Bill Under An Established Chiropractor’s NPI?

Many chiropractic practices mistakenly believe a newly hired chiropractor can bill under an established chiropractor’s NPI while waiting for credentialing approval. In most cases, this is not permitted. Claims should be submitted under the NPI of the chiropractor who actually rendered the service to avoid compliance risks, including potential False Claims Act exposure. This article outlines key billing rules, common exceptions, and practical compliance tips for chiropractic practices.

RNs and APRNs Take Note: Ohio Board of Nursing Mandates a New CE Reporting Period

Ohio’s Board of Nursing has updated the continuing education reporting period for RNs and APRNs. Beginning March 26, 2026, CE credits must be completed between July 1 and June 30 of odd-numbered years, replacing the previous November to October timeframe.

Ohio Med Spas: Peptide Do's and Do Not's

Recent guidance from the Ohio Board of Pharmacy outlines key compliance requirements for med spas using peptides. While some peptide drugs are FDA approved, others are not or cannot be compounded. Med spa operators should ensure they source medications from licensed suppliers, avoid non-approved or “research use only” products, and follow all compounding and storage regulations to maintain compliance and avoid enforcement actions.