Maryland: Ownership and Oversight
FPA since 2015 (18-month mentor for new NPs) + 2024 PA modernization. Maryland took NPs fully independent a decade ago, leaving only an 18-month mentorship for first-ever certifications, and in late 2024 replaced PA delegation agreements with collaboration agreements that never touch the Board.
Who the statute actually covers
- NP full practice authority (Full Practice Authority Act of 2015, Ch. 468; Health Occ. Title 8; COMAR 10.27.07): no attestation, no collaboration agreement, no physician relationship; the Board of Nursing is the sole regulator; prescribing includes Schedules II–V.
- "Mentor" (COMAR 10.27.07.01(B)(7), .02(A)(4)): for applicants never before certified as an NP in any state, a Maryland-licensed CRNP or physician with 3+ years of clinical experience, identified on the application and available for advice, consultation, and collaboration as needed for 18 months from application receipt. It is a named availability relationship — not supervision, chart review, or an agreement.
- "Collaboration agreement" (PA Modernization Act of 2024, HB 806, effective Oct. 1, 2024): the PA-side instrument replacing delegation agreements; executed with one or more patient care team physicians, kept on file at the practice setting, immediately producible to the Board of Physicians on request, but not submitted for Board approval and carrying no fee. Existing delegation agreements were grandfathered as collaboration agreements.
1. Who can own what
| Entity / Path | Who may own | Key limits |
|---|---|---|
| Physician practice entities | Professional corporations and PLLCs owned by licensees (Md. Corps. & Ass'ns, Title 5); Board of Physicians polices lay control of clinical judgment. | Verify cross-profession combinations under current Maryland entity law before mixing license types. |
| NP-owned practice | Fully viable with zero physician involvement; a decade of FPA means MD NP-owned primary care, psych, and telehealth practices are routine. | New-to-practice NP founders still need their 18-month mentor named on the initial application. |
| PA path | No ownership lane into medical entities; PAs practice under collaboration agreements with patient care team physicians. | |
| Lay / MSO | Professional-entity rules and Board oversight keep lay actors out of clinical control; MSO model standard. |
2. Collaborative and supervisory oversight
| Role | Agreement required | Oversight mechanics | Path to independence |
|---|---|---|---|
| PA | Written collaboration agreement with one or more patient care team physicians (2024 Act); kept at the practice setting, produced to the Board on request; Board notified per the Act's notice provisions; no Board approval or fee. | Mechanics (scope, consultation, review) are agreement-defined; no statutory chart-review percentage. Verify current COMAR for any concurrent-PA limits, as Board rulemaking implementing the 2024 Act has continued. | None. The collaboration agreement requirement is permanent. |
| NP | None for experienced NPs. First-ever certification applicants: named mentor (CRNP or physician, 3+ years experience, MD-licensed) available as needed for 18 months from application. | No agreements, ratios, chart reviews, or filings; full independent prescribing II–V with CDS registration. | Independent at certification; the mentorship expires on its own at 18 months with nothing to file. |
3. Primary authorities
- Nurse Practitioner Full Practice Authority Act of 2015 (Ch. 468; SB 723/HB 999); Health Occ. Title 8; COMAR 10.27.07.
- Physician Assistant Modernization Act of 2024 (HB 806, eff. Oct. 1, 2024); Maryland Board of Physicians implementation guidance.
- Md. Corps. & Ass'ns, Title 5 (professional entities).
Practical read: Maryland is the low-friction Mid-Atlantic state: the NP side needs nothing after the first 18 months of a career, and the PA side's paperwork never leaves the building. Two mistakes worth flagging: treating the mentor requirement as a collaboration agreement (it is not, and papering it like one creates obligations Maryland never imposed), and assuming the 2024 PA changes eliminated the agreement itself rather than just the Board filing.
General education, not legal advice.