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Physician Assistant Collaboration Requirements in Illinois

A summary of Illinois’s collaboration, agreement, filing, supervision, prescribing, and specialty rules for PAs and the physicians who collaborate with them.

illinois np/pa collaboration laws
State Overview
Illinois PA Collaboration Laws Overview
collaborating physician required

Collaborating Physician Required? Yes in most settings

physician involvement

Physician Involvement: High

NP collaborative agreement

Agreement Name: Written collaborative agreement

proximity requirements

On-Site Requirements: None generally

chart reviews

Chart Review: No fixed count

controlled substances

Controlled Substances: Allowed where delegated

transition requirements

Reduced Supervision / Transition Requirements: None

State Requirements Summary

Illinois PA Collaboration Requirements Summary

 

Illinois requires PAs to practice with a collaborating physician under a written collaborative agreement in most settings, with a notable carve-out: PAs working in hospitals and federally qualified health centers are not required to have one. Involvement is high — the physician must provide consultation at least monthly, jointly build and approve the orders or guidelines the PA works from, and periodically review the services delivered under them. Day-to-day location is flexible: the physician does not need to be on-site as long as they are reachable for consultation, though the agreement must flag any procedures that require the physician’s presence. The agreement itself is never filed with the Department, but the physician does have to file notices of collaboration, delegated prescriptive authority, and termination. This page covers Illinois’s rules on collaboration, the written collaborative agreement, board filing, ongoing compliance, prescribing, and specialty and telehealth requirements.

 

Source: 225 ILCS 95/7.5(a)

Collaboration Type

Type of Collaborative Relationship

 

Illinois requires PAs to work with a collaborating physician who keeps final responsibility for patient care and for the PA’s performance, and there is no route to independent practice. Involvement is high: monthly consultation, jointly approved orders, and periodic review of the services provided under them. A PA’s authority comes from what the physician delegates within that physician’s own specialty, and one physician may collaborate with up to seven full-time-equivalent PAs outside certain facility settings.

 

Source: 225 ILCS 95/4(3),(3.5)

 

What is a PA’s scope of practice in Illinois?

 

A PA’s scope of practice is what the collaborating physician delegates within that physician’s own specialty. The written collaborative agreement describes the working relationship and the categories of care, treatment, or procedures the PA will provide. Delegated tasks must be consistent with the PA’s education, training, and experience, and must be services the collaborating physician is authorized to and generally provides in normal practice.

 

Do PAs need a collaborating physician in Illinois?

 

Yes in most settings, but not every setting requires a written collaborative agreement. PAs practicing in hospitals and federally qualified health centers are exempt from the written collaborative agreement requirement. Everywhere else, a written collaborative agreement with a collaborating physician is required.

 

Can PAs practice independently in Illinois?

 

No. Illinois has no independent or autonomous practice option for PAs and no transition pathway that reduces oversight over time. The collaborating physician maintains final responsibility for the care of the patient and for the PA’s performance, and a PA may take on patient care responsibilities only for that physician’s patients.

 

How many PAs can a physician collaborate with in Illinois?

 

A physician may enter into written collaborative agreements with no more than seven full-time-equivalent PAs. That cap does not apply in a hospital, hospital affiliate, or ambulatory surgical treatment center. A physician may also exceed seven when the services are provided in a federal primary care health professional shortage area with a score of 12 or higher, and must keep documentation of that exemption for the Department.

 

Who can be a collaborating physician in Illinois?

 

The collaborating physician must be licensed to practice medicine in all its branches and be engaged in clinical practice. The physician may only delegate procedures that fall within their own specialty, and the delegated tasks must match the PA’s education, training, and experience.

 

Are there proximity or in-person requirements in Illinois?

 

No — Illinois sets no geographic or travel requirement. The collaborating physician does not have to be personally present where services are rendered, as long as communication is available for consultation by radio, telephone, or other telecommunication within the guidelines the physician and PA have set. The written collaborative agreement must, however, specify which authorized procedures require the physician to be present while they are performed.

 

Agreements

Collaboration Agreement Requirements

 

Illinois’s written agreement is called a written collaborative agreement, and the state provides no template. Both the collaborating physician and the PA sign it. It does not have to be kept on-site, but both parties must be able to produce a copy to the Department on request, and Illinois sets no fixed review or renewal schedule.

 

Source: 68 Ill. Admin. Code § 1350.55(d)

 

What must be included in a PA collaborative agreement in Illinois?

 

The agreement must describe the working relationship between the PA and the collaborating physician and the categories of care, treatment, or procedures the PA will provide, and must promote the PA’s exercise of professional judgment commensurate with their education and experience. It must specify which authorized procedures require the physician to be present as they are performed, and must state whether the physician has delegated prescriptive authority for legend drugs and/or any schedule of controlled substances. Illinois treats the agreement as adequate when the physician jointly formulates and approves orders or guidelines with the PA, periodically reviews them and the services provided under them, and provides consultation at least once a month.

 

What is the collaborative agreement called in Illinois?

 

It is called a written collaborative agreement. Illinois’s administrative rules also use the term written guidelines for the same document, and the state provides no sample form.

 

Who has to sign the collaborative agreement in Illinois?

 

The collaborating physician and the PA must both sign.

 

How often must the agreement be reviewed or renewed in Illinois?

 

Illinois sets no specific review or renewal requirement for the agreement itself. The physician must periodically review the jointly approved orders and the services provided to patients under them. A PA must also tell each collaborating physician about every written collaborative agreement they have signed, and provide copies on request.

 

Is a backup physician required in Illinois?

 

No — Illinois’s rules are silent on backup or alternate collaborating physicians. Illinois does address the gap a different way: if a written collaborative agreement terminates, the PA may continue practicing for up to 90 days, provided they seek any necessary collaboration at a local hospital and refer patients who need care beyond their training and experience.

Board Filing

Board Filing Requirements

 

Illinois does not require the written collaborative agreement to be filed — but the collaborating physician does have to file several notices with the Department. Those are a notice of employment or collaboration, a notice of delegated prescriptive authority, and, when things end, a notice of termination. The employment or collaboration notice carries a 60-day deadline; termination carries a 10-day deadline.

 

Source: 225 ILCS 95/6(d)

 

Do you have to file the collaborative agreement with the board in Illinois?

 

No. The written collaborative agreement itself is never filed. The collaborating physician must instead file notice of employment or collaboration with a PA, and a separate notice of delegation of prescriptive authority specifying what has been delegated.

 

Can a PA start practicing as soon as they file in Illinois?

 

Yes — Illinois’s statute expressly says nothing prevents a PA from beginning employment before the notice of employment or collaboration has been filed. The collaborating physician has 60 days from the start of employment or collaboration to file that notice.

 

What are the termination and notice requirements in Illinois?

 

The collaborating physician must file a termination notice with the Department within 10 days of ending the collaboration or the delegated prescriptive authority. Separately, a PA whose written collaborative agreement terminates may keep practicing for up to 90 days, provided they seek any necessary collaboration at a local hospital and refer patients who need services beyond their training and experience.

Compliance

Collaboration Compliance

 

Illinois’s central ongoing obligation is monthly consultation between the PA and the collaborating physician. Alongside that, the physician must jointly formulate and approve the orders or guidelines the PA works from and periodically review those orders and the services provided under them. Illinois requires no chart co-signature, sets no separate documentation requirement, and fixes no retention period.

 

Source: 225 ILCS 95/7.5(a)(2)

 

How many charts must a collaborating physician review in Illinois?

 

There is no fixed chart count, though review is required. The collaborating physician must jointly formulate and approve orders or guidelines with the PA and then periodically review those orders and the services provided to patients under them, measured against accepted standards of medical and PA practice. Chart co-signature is not required.

 

How often must a PA and collaborating physician meet in Illinois?

 

At least once a month — the collaborating physician must provide consultation monthly. If the PA prescribes controlled substances, they must also discuss the condition of every patient receiving one with the collaborating physician each month.

 

How long must collaboration records be kept in Illinois?

 

Illinois sets no specific retention period and no separate supervision documentation requirement. Both the PA and the collaborating physician must be able to produce a copy of the signed written collaborative agreement to the Department on request, and a physician relying on the shortage-area exception to the seven-PA cap must keep documentation of it.

Prescribing

Prescribing Rules

 

PAs in Illinois may prescribe only to the extent the collaborating physician delegates that authority in writing, and the agreement must state which schedules are covered. To prescribe controlled substances in Schedules II through V, the PA must obtain an Illinois mid-level practitioner controlled substances license; the collaborating physician must hold a current Illinois controlled substance license and federal DEA registration in order to make the delegation. Schedule II carries the tightest restrictions in Illinois — limited forms, named drugs, a 30-day cap, and monthly discussion.

 

Source: 225 ILCS 95/7.5(b)

 

Can a PA prescribe controlled substances in Illinois?

 

Yes, if the collaborating physician delegates that authority. The PA must obtain an Illinois mid-level practitioner controlled substances license to prescribe in Schedules II through V, and must meet the education requirements of the Illinois Controlled Substances Act. The written collaborative agreement must state that the physician has delegated prescriptive authority for legend drugs and/or specific schedules of controlled substances.

 

Can a PA prescribe Schedule II drugs in Illinois?

 

Yes, but narrowly — and only if the collaborating physician chooses to delegate it, which Illinois does not require them to do. Only oral, topical, or transdermal forms may be delegated; Schedule II drugs delivered by injection or other routes cannot be. The delegated drugs must be ones the collaborating physician routinely prescribes, must be identified specifically by brand or generic name, are capped at a 30-day supply, and any continuation needs the physician’s prior approval.

 

What schedule drugs can a PA prescribe in Illinois?

 

Legend (non-controlled) drugs and controlled substances in Schedules II through V, to the extent the collaborating physician delegates each. The written collaborative agreement has to spell out which schedules are covered. Schedule II carries the additional form, naming, quantity, and approval limits described above.

 

Does a PA need a DEA license in Illinois?


Illinois requires the PA to obtain a state credential — a mid-level practitioner controlled substances license — to prescribe Schedules II through V.
The federal DEA registration named in Illinois’s PA rules is a requirement on the collaborating physician, who must hold both it and a current Illinois controlled substance license in order to delegate prescriptive authority. Illinois’s PA rules do not separately state a federal DEA registration requirement for the PA, so confirm federal requirements directly before prescribing.

 

Can a PA prescribe independently (without physician sign-off) in Illinois?

 

No. Prescriptive authority exists only as delegated in writing by the collaborating physician, who retains final responsibility for patient care. Individual prescriptions do not require co-signature, but every controlled substance prescription must be discussed with the physician monthly, and continuing a Schedule II prescription past 30 days requires the physician’s prior approval.

Specialty & Telehealth

Specialty & Telehealth Requirements

 

Illinois sets no telehealth-specific or specialty-specific requirements for PAs. The standard collaboration, agreement, filing, compliance, and prescribing rules apply the same way regardless of specialty or how care is delivered.

 

Source: 225 ILCS 95 (Physician Assistant Practice Act; Illinois sets no specialty- or telehealth-specific provision for PAs)

 

Are there telehealth or telemedicine requirements for PAs in Illinois?

 

No — Illinois sets no specific telehealth or telemedicine requirement for PAs. The state’s general availability standard already allows for remote contact: the collaborating physician may satisfy it by being reachable for consultation by radio, telephone, or other telecommunication rather than being present.

 

Are there specialty-specific requirements for PAs in Illinois?

 

No — Illinois sets no specialty-specific requirement for PAs. Specialty still shapes the relationship, though: a collaborating physician may only delegate procedures that fall within their own specialty, and the services delegated must be ones that physician generally provides in normal practice.

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