Alert: Illinois Adopts Final Rules For Full Practice Authority for Advanced Practice Registered Nurses

July 12, 2019

In 2017, the State of Illinois passed legislation which allowed Advanced Practice Registered Nurses (“NP”) to apply for full practice authority, effective January 1, 2018. Conceptually, this would allow a NP to own a medical practice. Unfortunately for the NP community, many sleepless nights passed before the State finally released the administrative rules on the process to obtain full practice authority.

On June 14, 2019, the much anticipated 68 page administrative rules were finally released. These final rules include filing fees and notarized attestations to the board of completion of the following: (1) 250 hours of continuing education and training in the NP’s area of certification, and (2) at least 4,000 hours of clinical experience in their area of certification that is in collaboration with and certified by a physician(s). Additional continuing medical education, an Illinois controlled substance license, and a federal Drug Enforcement Administration number will be required. These regulations do not change the rules for ownership of professional entities. As such, a NP cannot own or jointly own a medical practice with physicians. However, a strong argument can now be made that a NP could own a facility that is indistinguishable from a medical spa. We would not recommend that a NP market it as “med” or “medical” based on the IL advertising rules. It would more accurately be termed an “advanced nursing spa” or “aesthetic nursing practice”.

In the event a NP in IL desires to own their own facility, only after complying with these rules may a NP have full practice authority and practice without a collaboration agreement. You can read the current version of the statute here and the newly adopted version of the rules here.

If you have any questions or would like to know more about the proposed rules, please schedule a consult at

ByrdAdatto Founding Partner Bradford E. Adatto

Bradford E. Adatto

Brad decided to become a lawyer during sixth-grade Career Day, when he promised to represent his best friend, a future doctor. A few decades later, he started his own law firm that focused on representing health care and corporate clients.