PMHNP Practice Authority in Illinois: Independence, Physician Agreements and Schedule II

AANP's May 2026 map classes Illinois as reduced.

The legal fact behind the label is 225 ILCS 65/65-35(a): a written collaborative agreement is required for all APRNs engaged in clinical practice prior to meeting the requirements of Section 65-43.

The tier misses two things the statute provides.

APRNs privileged to practise in a hospital, hospital affiliate or ambulatory surgical treatment center are excepted outright, though an APRN who practises outside the hospital they are privileged in needs the agreement for that outside practice (65-35(a-5)).

And the agreement is not career-long: Section 65-43 ends it once the transition requirements are met.

A new graduate therefore starts under the agreement; an experienced APRN relocating to Illinois can plan the attestation from day one.

The exit is an attestation, not a new licence.

An APRN who files with the Department a notarized attestation of at least 250 hours of continuing education or training and at least 4,000 hours of clinical experience after first attaining national certification no longer requires a written collaborative agreement.

Both counts run in the APRN's area of certification: the continuing education as set forth by Department rule, and the clinical experience in collaboration with a physician or physicians, attested by the collaborating physician or physicians or the employer and the APRN — with the Department able to accept other evidence by rule where they cannot attest.

Start counting at national certification, not at RN licensure or graduate school.

What the attestation unlocks is the whole ladder: practising in all practice settings consistent with national certification and prescribing legend drugs and Schedule II through V controlled substances without the agreement.

The agreement describes the relationship with the collaborating physician and the categories of care, treatment or procedures the APRN will provide, and it is not construed to require the physician's personal presence where services are rendered — consultation happens in person or by telecommunications or electronic communications.

Absent an employment relationship, it cannot restrict the categories of patients within the APRN's training and experience, limit payors, or limit the geographic area or practice location in Illinois.

65-35(d) requires only that both parties make a copy of the agreement available to the Department on request; the delegation of prescriptive authority is noticed to the Department and the Prescription Monitoring Program (65-40(c)).

The collaborating physician must have access to the medical records of all patients the APRN attends, and where prescribing is delegated, medication orders are reviewed periodically by the collaborating physician (65-40(b)).

No set chart-review percentage is located in the sources read, and the only numeric cap in the delegation section — no more than 7 full-time equivalent physician assistants — is written for PAs, not APRNs.

Under a collaborative agreement the physician may, but is not required to, delegate Schedules III through V; Schedule II only by specific delegation — named substances the collaborating physician routinely prescribes, oral, topical or transdermal application (injection may not be delegated), no more than a 30-day supply, continuation only after the physician's prior approval, and a monthly discussion of any controlled-substance patient.

With full practice authority the picture flips: legend drugs and Schedule II through V are the APRN's own authority.

Schedule II narcotic drugs, such as opioids, keep conditions: named drug (brand or generic), oral, topical or transdermal application only (injection not permitted), and a consultation relationship with a physician recorded in the Prescription Monitoring Program, with at least monthly patient discussions.

ADHD stimulants such as amphetamine and methylphenidate are not opioids or other narcotics caught by that condition, so a full-practice outpatient PMHNP can prescribe them under their own authority.

With full practice authority, benzodiazepines: up to a 120-day supply without a consultation relationship; continued prescription requires consultation with a physician (65-43(c)(4.5)).

An Illinois PMHNP registers with the DEA as a mid-level practitioner, and that registration covers only the schedules Illinois lets the APRN prescribe.

Illinois layers its own registration on top: a mid-level practitioner controlled substance license under the collaborative route, and with full practice authority, statutory authority to obtain an Illinois controlled substance license and a federal Drug Enforcement Administration number (65-43(c)(5)).

The DEA and HHS telemedicine flexibilities, extended through December 31, 2026, let registered practitioners prescribe Schedules II through V remotely without an in-person evaluation, but they lift no state limit — the collaborative agreement, the Schedule II delegation terms and the full-practice narcotic-consultation rule all still apply.

Illinois has not enacted the APRN Compact — it is not among the five enacting states found (Delaware, North Dakota, South Dakota, Utah and Wyoming).

The compact comes into effect only when seven states enact it, so no APRN holds a multistate APRN licence today.

The Nurse Licensure Compact is an RN compact and gives no nurse practitioner authority.

A PMHNP moving to Illinois needs an Illinois APRN licence from IDFPR and, until the Section 65-43 attestation is filed, an Illinois written collaborative agreement.

Four amendments touch the rules on this page: Section 65-43 by P.A.

103-60, effective January 1, 2024 (the content of that amendment was not isolated in the sources read); Section 65-35 by P.A.

104-244, effective January 1, 2026 (the text read includes the home-birth certified nurse midwife provisions in subsection (b-10), a CNM rule rather than a PMHNP one; the content of that amendment was also not isolated); and 60/54.5 by P.A.

103-228, effective January 1, 2024, and P.A.

104-796, effective August 7, 2026.

The bigger planning fact sits in the section headings: Sections 65-35, 65-40 and 65-43 each carry the notice that they are scheduled to be repealed on January 1, 2028, while 60/54.5 carries its own repeal notice of January 1, 2032.

Nothing read says whether the 2028 sunset will be extended — check for reenactment before relying on either route past that date.