Virginia: Ownership and Oversight
Patient care team model with a 3-year NP exit (2024). Virginia runs a transition-to-practice system administered jointly by the Boards of Medicine and Nursing: NPs collaborate under practice agreements until an attested three years of full-time experience, then practice autonomously. The 2024 legislation cut the threshold from five years and added NP-to-NP succession mechanics.
Who the statute actually covers
- "Patient care team physician" (Va. Code §§ 54.1-2900, 54.1-2957): the physician providing collaboration and consultation to an NP under a written or electronic practice agreement. The agreement is not filed with either Board; both parties keep copies.
- The ratio (§ 54.1-2957): a physician may not serve as patient care team physician to more than 6 NPs with prescriptive authority at one time, except up to 10 psychiatric-mental health NPs. Autonomous NPs and non-prescribing NPs do not count.
- "Autonomous practice" (§ 54.1-2957(I); 18VAC90-30-86, as amended by HB 971 (2024)): practice without a practice agreement after the equivalent of 3 years of full-time clinical experience (1,800 hours/year standard), per licensure category, evidenced by attestation from the patient care team physician, or in defined circumstances from a qualified attesting NP. Applications before July 1, 2024 required 5 years; the temporary 2-year COVID window has closed.
- Continuity rules (§ 54.1-2957(G)): if the patient care team physician dies, retires, loses licensure, or relocates, the NP may continue up to 60 days on Board notice (extendable), prescribing only what the prior agreement authorized. HB 971 added succession under a qualified autonomous NP.
1. Who can own what
| Entity / Path | Who may own | Key limits |
|---|---|---|
| Physician practice entities | Professional corporations and PLCs owned by licensees (Va. Code § 13.1-542 et seq.; § 13.1-1100 et seq.). | Verify permitted cross-profession combinations before mixing license types. |
| NP-owned practice | Viable; autonomous NPs own and run practices with no physician relationship, and pre-autonomous NPs own practices while maintaining practice agreements. | The practice agreement documentation doubles as evidence for the eventual autonomy attestation; keep it clean from day one. |
| PA path | PAs practice on patient care teams under collaboration agreements (§§ 54.1-2951 et seq.); no ownership lane into medical entities. | |
| Lay / MSO | Professional-entity rules keep lay owners out of the clinical entity; MSO model standard at FMV. |
2. Collaborative and supervisory oversight
| Role | Agreement required | Oversight mechanics | Path to independence |
|---|---|---|---|
| PA | Written or electronic practice/collaboration agreement with a patient care team physician (§§ 54.1-2951 to -2952); mechanics agreement-defined. | No statutory chart-review percentage; telemedicine collaboration expressly permitted. Verify current Board of Medicine rules for any PA-count limits. | None for PAs under current law. |
| NP | Written or electronic practice agreement with a patient care team physician until autonomy; prescribing of Schedules II–VI per the agreement and certification category (§ 54.1-2957.01). Not filed; retained by both parties. | Ratio: 6 prescribing NPs per physician (10 for PMHNPs); autonomous NPs excluded. 60-day continuation on loss of the physician. CNMs exit after 1,000 hours via attestation; CRNAs remain under supervision. | Yes: autonomous practice after 3 years full-time via attestation (§ 54.1-2957(I); HB 971, 2024). Endorsement applicants qualify with 3 years under prior state's laws. |
3. Primary authorities
- Va. Code § 54.1-2957; § 54.1-2957.01.
- 18VAC90-30-86; HB 793 (2018); HB 971 (2024).
- Va. Code §§ 54.1-2951 to -2952; § 13.1-542 et seq.
Practical read: Virginia is now a three-year sentence, not five, and the attestation is the asset: an NP who tracks hours, patient population, and practice area from day one walks into autonomy on schedule. For staffing models, count only prescribing, non-autonomous NPs against the 6-cap, and remember psychiatric NPs get their own 10-slot lane.
General education, not legal advice.