Supervising Physician Cheat Sheet for Vermont
Requirements for Supervising Physician agreements in Vermont, plus a free agreement builder tailored to Vermont law.
Provider supervision requirements in Vermont
Updated 2026-09-03
Provided for educational and research purposes only — this is not legal advice. Laws and regulations change frequently, and this content may contain errors or omissions. Always confirm current requirements with a licensed attorney before relying on this for compliance decisions.
H.583 (signed June 15, 2026, eff. July 1, 2026) newly restricts private-equity/hedge-fund control and requires majority physician ownership/governance of medical practices — a major shift from Vermont's historically permissive, no-common-law-CPOM stance. All 4 APRN roles (NP, CRNA, CNM, CNS/PMHNP) share one 2,400-hour/2-year transition-to-practice threshold (26 V.S.A. § 1614) — treat as newly in effect and monitor implementing guidance.
Physician Assistant
Vermont has no autonomous/independent-practice pathway for PAs based on experience or hours — a PA must maintain a practice agreement with one 'participating physician' throughout their career, per 26 V.S.A. § 1735a, except in narrow settings listed in §§ 1734c(b)/1735a(e) (e.g. certain hospital-employed PAs).
Proximity
Available remotely (no on-site requirement)
The participating physician must be 'accessible for consultation by telephone or electronic means at all times' the PA is practicing (26 V.S.A. § 1735a); no on-site or mile/minute standard is codified.Chart review
Not codified — left to the practice agreement
Prescriptive authority
Covered by practice agreement · controlled substances permitted
A PA may prescribe, dispense, administer, and procure drugs and medical devices 'to the same extent as a physician'; a PA who prescribes controlled substances must hold federal DEA registration. No schedule-specific numeric limit found in statute. Separately, § 1735a requires the practice agreement to include processes for 'periodic joint evaluation of services delivered,' but codifies no fixed meeting frequency — left to the agreement.Practice ownership (CPOM)
Licensee-only ownership required — Professional Corporation under 11 V.S.A. ch. 4 (§ 1403 lets licensed physicians hold shares in a PC providing medical and nursing services). As of H.583 (eff. July 1, 2026), a medical practice may only employ physicians/practice medicine if Vermont licensees hold a majority of shares, a majority of directors, and all officer positions except secretary/treasurer, with each licensed owner meeting a 'meaningful ownership' (in-state, substantially engaged) standard. Whether a PA is independently eligible as a PC shareholder alongside a physician was not separately confirmed.
H.583 also adds PE/hedge-fund ownership reporting (to the Green Mountain Care Board, starting March 2027) and a private right of action for providers whose clinical judgment is interfered with by a non-licensee owner.Supervision ratio
Not codified — left to the practice agreement
Meeting cadence
Not codified — left to the practice agreement
Written agreement
Required
Legal sources
$650–$950/mo
Estimated PA supervision cost in Vermont
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