New Hampshire: Ownership and Oversight
Full FPA from licensure — the zero-friction state. New Hampshire is one of the oldest and cleanest full practice authority states: APRN independence attaches at licensure with no transition period, no agreement, and no physician anywhere in the framework.
Who the Statute Actually Covers
- APRN independence (RSA 326-B:18): APRNs practice and prescribe (including Schedules II–V with DEA registration) under Board of Nursing authority alone; no collaborative or supervisory agreement, no transition hours, no ratios, no chart review, at any career stage. New Hampshire has held this framework since 2009, making it one of the most settled FPA environments in the country.
- PA framework (RSA 328-D): PAs practice in collaboration with physicians; agreement mechanics and the degree of collaboration are set at the practice level; verify current statutory agreement requirements with the Board of Medicine when drafting.
- Entity posture: licensee-owned professional entities under RSA 294-A (professional corporations) when that form is used; corporate practice policed through licensing law rather than a strong standalone doctrine.
1. Who Can Own What
| Entity / Path | Who May Own | Key Limits |
|---|---|---|
| Professional entities | Professional corporations under RSA 294-A, licensee-owned. | Verify combinations with New Hampshire counsel. |
| NP-owned practice | Fully independent from licensure; New Hampshire is a longstanding destination for NP-owned direct care and psychiatric practices precisely because nothing expires, transitions, or renews. | — |
| PA path | Collaboration framework; no ownership prohibition in the practice act — structure with local counsel. | — |
| Lay / MSO | Low-friction; standard fee-splitting and referral rules apply. | — |
2. Collaborative and Supervisory Oversight
| Role | Agreement Required | Oversight Mechanics | Path to Independence |
|---|---|---|---|
| PA | Physician collaboration per RSA 328-D with practice-level mechanics. | No ratio; no statutory chart-review percentage; verify current agreement content requirements with the Board of Medicine. | None formalized; the collaboration framework is practice-defined. |
| NP / APRN | None. Full practice authority from licensure (RSA 326-B:18). | No agreements, ratios, transition hours, or review requirements ever. | Independent from day one. |
3. Primary Authorities
- RSA 326-B:18 (APRN practice and prescriptive authority; FPA since 2009).
- RSA 328-D (physician assistants); RSA 294-A (professional corporations).
Practical read: New Hampshire is the stability play — NP independence is statutory, permanent, and old enough to be boring, which is exactly what a founder wants under a practice. When clients compare New England states for an NP-led launch, New Hampshire and Rhode Island are the no-on-ramp options; Maine and Vermont have short ones; Connecticut and Massachusetts make you earn it.
General education, not legal advice. Verify current statutes, board rules, and opinions before relying on this summary.