On Sept. 21, the Louisiana State Board of Medical Examiners filed a notice of intent in the Louisiana Register to amend the medical board rules regarding the collaborative practice agreement. This new rule would significantly restrict APRNs.

All public comments must be received by Oct. 21 by mailed to LSBME, C/O Jacintha Duthu, 630 Camp St., New Orleans, LA 70130 or email jduthu@lsbme.la.gov.

Below is a list of concerns regarding the rulemaking. Click here for a redline version of the rulemaking. 

1. Use of “Supervision” in the Collaborative Relationship

The proposed language states that an APRN practices “under the supervision of the collaborating physician.” The current relationship is one of collaboration, not supervision, and “supervision” is not clearly defined within the proposed rule. This could create uncertainty regarding clinical responsibility, professional accountability, liability, and APRN decision making. 

2. Expanded Collaborative Practice Agreement Requirements

The proposal adds several requirements to CPAs, including documentation plans, hospital privilege arrangements, expanded physician availability and management of complications, patient notification, and public disclosure.

Some of these provisions duplicate requirements already addressed through hospital credentialing, facility policies, or existing regulations while creating additional administrative burdens. The requirement that a collaborating physician participate in the “management of complications of treatment” also raises questions about the physician’s responsibility and liability for patients with whom they may have no established provider relationship.

These additional requirements could have a disproportionate impact on APRN-owned practices and providers serving rural, Medicaid, developmental disability, and other underserved populations.

3. Regulatory Authority and Complaints

The proposal states that complaints received by LSBME involving a CPA or collaborating APRN would be processed in the same manner as complaints against physicians. LSBN already licenses and regulates APRNs. This would be a significant change to the current regulatory structure.