Yes, within limits. Colorado’s Nurse Practice Act does not require an advanced practice registered nurse to sign a collaborative or supervisory agreement with a physician. A nurse practitioner with prescriptive authority may examine, prescribe and treat within the NP’s role and population focus. The limits are the prescribing mentorship, scope, dispensing, delegation, and who may own which entity.
Each limit below is in the statute as of October 2026.
The statute asks for a consultation mechanism
Section 12-255-111(5) sets the standard. An APRN “shall practice in accordance with the standards of the appropriate national professional nursing organization and have a safe mechanism for consultation or collaboration with a physician or, when appropriate, referral to a physician.”
That sentence does not require a signed agreement, a supervising physician, chart co-signature or a ratio. It requires that you can show how you consult and refer. Write it down: who you call, where you refer, and how fast.
Section 12-255-113 adds a second condition. An APRN “engaged in an independent practice” must carry professional liability insurance at the level the statute sets, covering all acts within the APRN’s scope.
Prescriptive authority is the real gate
A med spa runs on prescription products: neurotoxins, fillers, GLP-1s, IV ingredients. Being on the advanced practice registry does not carry prescribing. Section 12-255-112(10) says an APRN is not required to obtain it, and § 12-255-112 sets out how to get it.
- Apply with the evidence in (4)(a). Graduate degree, education in prescribing, national certification, liability insurance, registry inclusion, and a signed attestation of at least three years of combined clinical work experience as a professional nurse or APRN.
- Receive provisional prescriptive authority. It is limited to patients and medications appropriate to your role and population focus. Board of Nursing Rule 1.15 states that it includes controlled substances in Schedules II through V.
- Complete 750 hours of documented prescribing mentorship. The mentor may be a physician, or an APRN with full prescriptive authority. The mentor must practice in Colorado, with education, training and an active practice that corresponds to your role and focus. Remote contact counts if it is synchronous. Email does not count (§ 12-255-112(4)(b)(I)(A), (B)).
- Finish within three years. If you do not, the provisional authority expires (§ 12-255-112(4)(b)(I)(E)).
Two details matter to an NP opening a clinic. First, the mentor does not have to be a physician. Second, a mentor “shall not require payment or employment as a condition of entering into the mentorship relationship,” though reimbursement of reasonable expenses and time is allowed. Section 12-240-107(3)(s)(III) makes it unlawful for any person or entity to impose that condition.
One correction to what you may have read elsewhere. Many guides still list an “articulated plan” as a requirement for full authority. Section 12-255-112(4)(b)(II) now reads “Repealed,” and the term does not appear in the current text of Rule 1.15.
What the license covers and where it stops
| Question | Answer in Colorado | Source |
|---|---|---|
| Collaborative agreement with a physician required | No. A safe mechanism for consultation, collaboration or referral is required | § 12-255-111(5) |
| Prescribing | Only with prescriptive authority, within role and population focus | § 12-255-112(3)(a), (7)(c)(I) |
| Mentor during provisional period | Physician or full-authority APRN practicing in Colorado, 750 hours within three years | § 12-255-112(4)(b)(I) |
| Dispensing | Prescriptive authority does not permit dispensing or distribution, apart from the exceptions listed in statute and rule | § 12-255-112(9); Rule 1.15(I)(3) |
| Delegating to staff | Tasks within your own scope that do not require nursing judgment. Authority to select medications cannot be delegated | § 12-255-131(1), (2) |
| Delegating medical-aesthetic services to unlicensed staff | Sign, website and advertising notice, signed consent kept seven years | § 12-255-137 |
| Shares in a physician’s professional entity | No | § 12-240-138(1)(d)(I) |
Three rows deserve a closer look.
Scope follows your certification. Prescriptive authority “is limited to those patients appropriate to the nurse’s … scope of practice,” and may be withdrawn for prescribing outside it or “for other than a therapeutic purpose” (§ 12-255-112(7)(c)(I)). Your menu has to fit your role and population focus.
We did not locate a Board of Nursing rule or opinion that sorts aesthetic or weight-management services by NP specialty. Ask the Board, or counsel, before a psychiatric or neonatal NP builds an injectables menu.
Dispensing is narrower than prescribing. Section 12-255-112(9) says nothing in the section permits dispensing or distribution by an APRN except samples. Rule 1.15(I)(3) restates it and lists prepackaged drugs prepared and labeled by a pharmacist or registered manufacturer, free samples, and drugs distributed for administration as authorized by law. If your weight-management model has patients leaving with vials you stock and sell, have Colorado pharmacy counsel review it first.
Delegation is a nursing rule here. The Medical Board’s delegation rule, with its off-site protocol framework, governs physicians. Rule 1.17(B) says it does not govern people regulated by the Board of Nursing. Your authority to delegate comes from § 12-255-131: the task must be within your scope, must not require the delegatee to exercise nursing judgment, and you alone determine the supervision needed based on the patient, the delegatee and the task. Section 12-255-104(4.5) lets an RN or LPN carry out a plan of patient care you prescribe, including standing orders, within their own scope. That is the statutory route for an NP-led IV therapy or injectables team of licensed nurses.
Ownership is a separate question from practice
An NP cannot solve a scope gap by putting a physician on payroll. Section 12-240-121(1)(g)(I) makes it unprofessional conduct for a physician to practice medicine as the employee of, or in joint venture with, a person who does not hold a medical license, or a corporation other than a professional service corporation for the practice of medicine. An APRN cannot hold shares in that corporation either. Section 12-240-138(1)(d)(I) limits shareholders to physicians, with physician assistants in the minority.
HB26-1249 would have let APRNs, RNs and others hold shares in a medical-aesthetics corporation. The House Health & Human Services Committee postponed it indefinitely on March 25, 2026.
The Nurse Practice Act has no section equivalent to § 12-240-138. We did not find primary authority on what entity an APRN-owned practice must use or whether a lay partner may co-own it. Ask Colorado counsel before you file anything.
When you still want a physician
Three situations call for one:
- You are in the provisional period and want a physician mentor whose practice matches your focus.
- Your menu reaches past your population focus, or into services you want a physician to order. Those services then run through a physician-owned professional entity, with its own good faith exam and orders.
- Your consultation mechanism needs a name. Section 12-255-111(5) is easier to prove with an identified physician who has agreed to take the call.
MDside’s position: an NP with full prescriptive authority, practicing inside their focus in Colorado, does not need to rent a physician’s name, and we will say so on the first call. Where a physician is needed, the role should be real and defined. Our comparison of nurse practitioner and physician directors covers the trade-offs, and how we credential providers explains what we verify.
What this means for you
Confirm three things on the Board’s license lookup before you sign a lease: registry status, role and population focus, and whether prescriptive authority is provisional or full. If it is provisional, calendar the three-year deadline and get the mentorship agreement in writing with no payment or employment condition. Write your consultation and referral mechanism into your policies. Match the menu to your focus, review any in-house dispensing with counsel, and post the § 12-255-137 disclosures if unlicensed staff perform delegated aesthetic services. For anything outside your scope, see medical director services in Colorado.
Frequently asked questions
Does a nurse practitioner need a collaborating physician in Colorado?
No collaborative or supervisory agreement is required by the Nurse Practice Act. Section 12-255-111(5) requires an APRN to practice to national standards and to have a safe mechanism for consultation or collaboration with a physician or, when appropriate, referral to one. Prescribing separately requires prescriptive authority under § 12-255-112.
How many mentorship hours does a Colorado NP need for full prescriptive authority?
An APRN granted provisional prescriptive authority must complete 750 hours of documented experience in a mutually structured prescribing mentorship. The mentor may be a physician or an APRN with full prescriptive authority who practices in Colorado. The hours must be completed within three years or the provisional authority expires under § 12-255-112(4)(b)(I).
Can a nurse practitioner be the medical director of a Colorado med spa?
An APRN with prescriptive authority may examine, prescribe and delegate within the APRN’s own role and population focus, and § 12-255-137 expressly contemplates APRNs delegating medical-aesthetic services. An APRN cannot supervise services outside that scope and cannot employ a physician to cover them, because § 12-240-121(1)(g) restricts who may employ physicians.
Can a Colorado nurse practitioner dispense semaglutide from the clinic?
Section 12-255-112(9) states that APRN prescriptive authority does not permit dispensing or distribution except for samples, and Board of Nursing Rule 1.15(I)(3) lists narrow categories such as prepackaged drugs prepared and labeled by a pharmacist or registered manufacturer. Have Colorado pharmacy counsel review any in-house dispensing model before launch.
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This is general information, not legal advice. Rules vary by state and change. Confirm your own facts with counsel.