The collaborative practice agreement (CPA) is supposed to be a working relationship between two professionals. In practice, it sometimes isn’t. The physician is hard to reach, slow to respond, disengaged — or the relationship has deteriorated to the point where you question whether you have real oversight at all.
This guide covers what your legal obligations are when a CPA relationship breaks down, how to find a new collaborating physician, and what to do if the physician threatens to withdraw mid-contract.
First: understand what’s actually required
A collaborative practice agreement is a formal legal document that defines the scope of a nurse practitioner’s clinical authority in states that require physician oversight. What “collaboration” requires in practice — real-time availability, chart review percentage, response time — varies considerably by state.
In some states, the CPA requires the collaborating physician to be available by phone 24/7. In others, it specifies that the physician must review a percentage of charts within 30 days. In still others, the agreement is largely administrative — the NP has full clinical autonomy; the physician’s role is to co-sign selected records.
Before evaluating whether your relationship is “broken,” review your actual CPA document and your state’s NP practice regulations. Know what the agreement specifies and what the state requires. These are separate questions.
What to look for in your CPA:
- Response time requirements for clinical consultation
- Chart review percentage and timeline
- Notice period required to terminate the agreement
- What happens to active patients if the agreement ends
- Which procedures or prescribing authorities require physician oversight vs. are NP-autonomous
If your CPA is vague on these points, that vagueness will work against you in a dispute.
Identify the type of breakdown
Not all deteriorating CPA relationships are the same, and the appropriate response depends on the nature of the problem.
The unavailable physician. The physician is technically still your collaborator but doesn’t respond to messages, skips chart reviews, or takes days to return calls. This is the most common scenario. The risk: if something goes wrong with a patient and the record shows you couldn’t reach your collaborator for a clinical question, your license exposure is significant.
The unresponsive-but-employed physician. In hospital-employed NP models, the collaborating physician is sometimes assigned administratively rather than chosen. When that physician changes employers or has schedule changes, the NP is left without a functional collaborator while the administrative paperwork still shows one.
The actively hostile relationship. The physician is discouraging patients from seeing you, undermining clinical decisions in front of staff, or refusing to support procedures that are within your state’s NP scope. This is both a clinical and a legal problem.
The threatened withdrawal. The physician has told you — explicitly or implicitly — that they will end the CPA relationship, possibly with inadequate notice. This is the highest-stakes scenario.
Your obligations during a CPA breakdown
You cannot simply continue practicing as if the CPA is intact if it has effectively broken down. Your obligations run in two directions: to your patients and to your license.
To patients: You have ongoing duty-of-care obligations to any patient who has an established relationship with your practice. You cannot abandon them. If the CPA is likely to end, you must develop a transition-of-care plan that gives patients adequate notice and time to establish care elsewhere.
State regulations on patient abandonment vary, but the general standard is 30 days’ written notice to patients of a practice closure or provider departure, with records maintained and available. Some states require longer. Check your state BON rules.
To your license: Practicing in a reduced-practice or restricted-practice state without an active, functional CPA is practicing outside your scope. Even if the physician is technically still listed on your CPA, if they are functionally unavailable and you’re not able to obtain consultation when needed, that gap is a liability.
Document every attempt to reach your collaborating physician. Date, time, mode of contact, and their response. This documentation becomes critical if you face a complaint.
Finding a new collaborating physician
The search for a collaborating physician is the most practically difficult part of this situation. Supply is limited in most markets, and many physicians are unwilling to take on collaborative responsibility for an NP they don’t know.
Where to look:
State medical association directories. Most state medical associations publish member directories searchable by specialty. Physicians who have previously collaborated with NPs are often willing to discuss new arrangements. A phone call to a practice manager is more effective than an email.
State NP association. Your state NP association often maintains informal lists of physicians who are known to be open to CPA arrangements. This is one of the most underused resources. Membership pays off here.
NP-focused Facebook groups and forums. Groups like “NP Business Owners” and specialty-specific NP communities frequently have threads where NPs share collaborator contacts by state. These referrals are vetted by peers.
Locum physician services. Several companies now specialize in providing physician collaborators for NP practices. Costs range from $300-$1,500 per month depending on the service model and level of actual oversight required. These are not oversight-free arrangements — the physician must be genuinely available — but they are a legitimate market solution. Search “physician collaboration services for NPs” or “NP collaborating physician service” for current providers.
Your employer or professional network. If you work in a group practice or hospital system, the organization’s medical director may be able to assign a new collaborating physician. This is the most straightforward path in an employed setting.
What to discuss before signing a new CPA:
- Their actual availability for clinical questions (response time expectations)
- Whether they will perform chart reviews themselves or delegate to staff
- The fee structure (if any)
- What they expect from you in terms of consultation frequency
- The termination notice period they expect to provide — and their track record on honoring it
A physician who hedges on these questions or who seems unfamiliar with NP scope of practice in your state is a poor candidate regardless of their willingness to sign.
What to do if the physician threatens to withdraw mid-contract
A physician threatening to end the CPA mid-contract is exercising a right that may exist in your agreement — but the notice period is what protects you.
Check your CPA for the termination clause. Most well-drafted CPAs require 30-90 days’ written notice from either party. If your agreement specifies 90 days and the physician says they’re out in two weeks, they are in breach of contract.
Send a written response immediately. State the contractual notice period. Request confirmation that they will honor it. Copy your malpractice insurance carrier.
Notify your malpractice insurer. Do this the same day. Your carrier needs to know that your CPA may be at risk. Many carrier contracts have requirements that you maintain compliant supervision — a gap in CPA coverage may affect your coverage status.
Notify your employer or practice administrator. If you’re employed, this is not your crisis to solve alone. Administration has an obligation to maintain compliant operations.
Begin the search for a replacement immediately. Do not wait for the notice period to expire before starting. 30 days is not much time to find, vet, and sign with a new collaborating physician.
If the physician refuses to honor the notice period: You have a contract dispute. This is a legal matter, and you should consult a healthcare attorney. In the meantime, document everything and consider whether you can continue operating safely while the dispute is resolved. If you cannot — because you genuinely cannot practice safely without a collaborator and none is available — you may need to suspend practice until the arrangement is resolved. Suspending practice is a significant step with its own implications, but practicing without a required CPA is worse.
How this differs by state restriction level
Full practice authority states (as of 2025 — approximately 27 states plus DC and Guam): NPs have autonomous practice and do not require a CPA. If your CPA relationship is deteriorating and you’re in a full-practice-authority state, you have options the following states do not. The most direct one: dissolve the CPA and practice independently. Check current state practice authority at the AANP State Practice Environment resource.
Reduced practice states: A CPA is required for some aspects of practice — typically prescribing or specific procedures. A breakdown in the CPA relationship limits your clinical authority in specific ways. The priority is replacing the collaborator; the scope of what you can do without one is state-specific.
Restricted practice states: The CPA is required for all NP practice. A CPA breakdown means you cannot legally practice at all until a new one is in place. These states — Alabama, Florida, South Carolina, and several others — offer the least runway. In restricted-practice states, the CPA termination notice period is your only real protection. Draft CPAs with the longest notice period you can negotiate.
The relocation option: If you are in a restricted-practice state and CPA relationships are consistently difficult to maintain, the structural fix is relocation. Full-practice-authority states allow NPs to operate without physician oversight, which eliminates CPA vulnerability entirely. This is a career-level decision, not a quick fix — but it is a real option that some NPs exercise specifically to escape the structural risk of CPA dependence. See the guide to autonomous practice state relocation for a framework.
Documenting the breakdown
Whatever else you do, document the breakdown in real time.
Create a dated log of every attempt to reach your collaborating physician. Note the mode of contact (text, phone, EHR message, email), what you asked about, and what response (if any) you received. This log has two purposes: it demonstrates due diligence if a clinical question arises, and it creates a contemporaneous record of physician non-responsiveness if you ever need to explain the relationship to a BON or in litigation.
If the physician is an employee of the same health system, use the EHR messaging system for all consultation requests — it timestamps automatically and is permanently attached to the patient record.
When to consult a healthcare attorney
Consult a healthcare attorney specializing in nursing or physician contracting when:
- The physician is in breach of your CPA’s notice period
- You are unsure whether your state requires active collaboration for the work you’re currently doing
- You have reason to believe the breakdown will lead to a BON complaint
- You’re considering suspending or limiting your practice
- Your malpractice insurer is asking questions
The cost of a 30-minute consultation with a healthcare attorney is small relative to the cost of a BON investigation or malpractice claim. Many state NP associations maintain referral lists.
Related resources
- Understanding your collaborative practice agreement
- NP independent practice states: what full practice authority actually means
- Relocating your NP practice to an autonomous practice state
Sources
- American Association of Nurse Practitioners. State practice environment. Available at: https://www.aanp.org/advocacy/state/state-practice-environment
- National Council of State Boards of Nursing. APRN practice. Available at: https://www.ncsbn.org/aprn.htm
- Buppert C. Nurse Practitioner’s Business Practice and Legal Guide. 7th ed. Burlington, MA: Jones & Bartlett Learning; 2021.
- American Association of Nurse Practitioners. Quality of nurse practitioner practice. Position statement. Available at: https://www.aanp.org/advocacy/advocacy-resource/position-statements