Colorado: Ownership and Oversight
Strict CPOM entity rules + full practice authority APRNs. An unusual combination: rigid physician-entity ownership rules sitting next to some of the most independent APRN practice law in the country. The ownership analysis and the scope analysis point in opposite directions.
Who the statute actually covers
- Medical professional entity shareholder (C.R.S. § 12-240-138): a physician licensed under the Colorado Medical Practice Act who is actively engaged in practice at the entity; passive physician shareholders are not permitted. The only cross-profession exception is PAs, minority only, with physicians keeping the majority.
- "RXN-P" and "RXN" (C.R.S. § 12-255-112): provisional prescriptive authority, then full prescriptive authority after a 750-hour documented prescribing mentorship (reduced from 1,000 in 2023) with a physician or full-RXN APRN mentor.
- PA collaboration threshold (C.R.S. § 12-240-114.5, 2023 modernization): a written collaborative agreement is required until the PA completes 5,760 practice hours (about 3 FTE years).
1. Who can own what
| Entity / Path | Who may own | Key limits |
|---|---|---|
| Medical PC / PLLC / LLP | Physicians only, each actively practicing at the entity. | Lay directors are barred from exercising clinical authority; corporate formalities cannot transfer clinical control. |
| PA co-ownership | PAs may hold minority interests alongside physicians who retain the majority. | The only non-physician lane into a Colorado medical entity. |
| NP ownership | NPs may not co-own a medical professional entity with physicians. APRNs organize their own nursing-category practices instead. | Full practice authority makes an APRN-owned practice operationally independent; the entity is a nursing practice, not a medical one. |
| Hospital employment | Hospitals may employ physicians (C.R.S. § 25-3-103.7) with protections for independent medical judgment. | The main statutory CPOM exception. |
| Lay / MSO | Not permitted in the professional entity. | MSO model works normally: FMV MSA, no clinical control. |
2. Collaborative and supervisory oversight
| Role | Agreement required | Oversight mechanics | Path to independence |
|---|---|---|---|
| PA | Written collaborative agreement with a physician until 5,760 practice hours are completed. | No numeric ratio. No statutory chart-review percentage; mechanics are agreement-defined during the transition period. | Partial: completing 5,760 hours ends the mandatory written agreement. |
| NP / APRN | None for practice: Colorado APRNs have full practice authority. Prescribing: provisional prescriptive authority (RXN-P), then a 750-hour documented prescribing mentorship, completed within 3 years, with an articulated plan; mentor compensation FMV. | No ratios, no chart-review percentages, no ongoing collaboration requirement after full RXN. | Yes: full prescriptive authority (RXN) after the 750-hour mentorship; practice authority is independent from day one. |
3. Primary authorities
- C.R.S. § 12-240-138; § 12-240-114.5; § 25-3-103.7.
- C.R.S. § 12-255-112 (APRN prescriptive authority; 750-hour mentorship).
- Colorado Medical Board and Board of Nursing rules (3 CCR 713).
Practical read: Colorado deals fail in two opposite ways: treating APRN independence as if it loosened the entity rules (it does not), or treating the entity rules as if they constrained APRN-owned nursing practices (they do not). Sort every Colorado question into entity or scope first.
General education, not legal advice.