Clinical Nurse Specialist Cheat Sheet for Virginia

Requirements for Supervising Physician agreements in Virginia, plus a free agreement builder tailored to Virginia law.

Provider supervision requirements in Virginia

Updated 2026-08-12

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.

No provider type below has a codified chart-review percentage, countersignature rule, or numeric proximity radius — all are left to the practice agreement. CPOM (ownership) is governed by Title 13.1's PC/PLLC statutes, which explicitly list APRNs (NP/CRNA/CNM/CNS) as eligible independent owners but do not enumerate PAs — the PA ownership pathway is an inference from that omission, not a confirmed holding. Virginia has no independent corporate-practice-of-medicine common-law doctrine (a 1992 AG opinion, secondary-sourced only).

Clinical Nurse Specialist

Independent practice requires: does not prescribe controlled substances or devices

Conditional independence

Uniquely among VA provider types, CNS independence turns on prescribing rather than experience/hours. A CNS who does not prescribe controlled substances/devices practices without any written practice agreement from licensure (full independence, subject to general consult/referral duties). A CNS who does prescribe controlled substances/devices must practice under a permanent practice agreement with a physician — unlike NP/PA/CNM, there is no attestation/hours-based exit from that requirement (§ 54.1-2957(J), 18VAC90-30-125).


Proximity

CNS who prescribes controlled substances/devices: Available remotely (no on-site requirement)

No codified mile/minute radius or on-site requirement; agreement need only address availability for routine and urgent consultation.

Chart review

Not codified — left to the practice agreement

Prescriptive authority

  • CNS who prescribes controlled substances/devices: Separate prescribing terms required · controlled substances permitted

    May prescribe Schedules II–VI per § 54.1-2957.01, but only pursuant to a permanent practice agreement with a physician — no independent-prescribing pathway exists for CNS.
  • CNS who does not prescribe controlled substances/devices: Covered by practice agreement · no controlled-substance authority

    Practices independently; no prescriptive authority for controlled substances.

Practice ownership (CPOM)

Licensee-only ownership required — Professional Limited Liability Company (PLLC) under § 13.1-1102 — CNSs, as an APRN category, are eligible independent PLLC owners; no physician ownership required. Alternatively a Professional Corporation under § 13.1-543 with all shares held by licensed/authorized individuals.

This ownership pathway applies regardless of the prescribing/non-prescribing branch above — it governs entity ownership, not clinical practice-agreement status.

Supervision ratio

Not codified — left to the practice agreement

Meeting cadence

Not codified — left to the practice agreement

Written agreement

Not required

Conditional, not unconditional — shown as 'Not required' for the default/non-prescribing branch, but a CNS who prescribes controlled substances/devices DOES need a permanent practice agreement with a physician, with no attestation/hours-based exit (see Prescriptive Authority below).

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