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

AANP's May 2026 map puts Maryland in its full practice tier, and AANP's November 2025 snapshot also lists Maryland among the full-practice states with a time-in-practice requirement.

Both are AANP's advocacy classifications; the legal text behind them is quieter than the labels suggest.

The practice rule the statute states is a standards-of-practice duty, quoted below, and the statute and regulation read contain no collaboration or supervision agreement.

For a PMHNP weighing a Maryland move, the licence itself does the work an agreement with a physician does in other jurisdictions.

The mentorship reaches one group only: an applicant for initial certification who has not been certified by the Maryland board or any other board of nursing.

The 18 months run from the date the Board receives the certification application — so the clock starts before certification, not after a first day of practice — and the duty is to identify the mentor on the application itself.

Nothing in the text read makes the 18 months a gate the applicant passes through before practising: no hours are counted, no supervision is exercised, and prescribing is not deferred behind the mentorship.

A PMHNP already certified in another state falls outside § 8-302.1(d)(1) entirely and applies without a mentor.

One boundary: COMAR 10.27.07.01 cross-references the Board's certification rule 10.27.07.02B(7), which was not read — treat the negatives as scoped to the sources cited here, and confirm with the Board.

If you are counting hours toward independence the way you would in an agreement state, the text read sets no clock and no threshold to count.

There is no collaborative or supervisory agreement in the sources read, and the mentor rule is not physician delegation, because COMAR lets the mentor be a certified nurse practitioner or a physician.

No ratio of APRNs per physician, no meeting frequency, no chart-review percentage and nothing filed with a medical board appears in the text read; COMAR's related definition frames “collaborating” broadly, as a cooperative relationship with other health care providers.

What the application does carry, from § 8-302.1(a) and (b): good moral character, a criminal history records check, an RN licence or a Nurse Licensure Compact multistate privilege, a Board-approved education program, graduation from a graduate-level accredited APRN program, certification by a Board-recognized national certifying body, English language competency, and any other requirements the Board sets under (b)(5).

For a new graduate choosing where to practise, the Maryland paperwork is an application and a named mentor — not a contract negotiated with a physician's office.

No Schedule II limit is located in the text read — an absence, not a grant of authority.

The sources read cover initial certification (Health Occ. § 8-302.1), the definitions in COMAR 10.27.07.01 and § 8-508's dispensing rules; the provisions that grant and condition CRNP prescribing were not among them, so whether an outpatient PMHNP may prescribe Schedule II ADHD stimulants is not established here — confirm authority with the Board before relying on it.

What the sources do carry is the dispensing side: Health Occ. § 8-508 covers starter dosages — a defined term, COMAR 10.27.07.01B(13): an amount sufficient to begin therapy of a short duration, 72 hours or less, or before obtaining a larger quantity to complete therapy — and, in listed settings (nonprofit, public health, campus health and workers' compensation), dispensing by nurse practitioners, who must “maintain a separate file for Schedule II prescriptions for a period of at least 5 years” and “Allow the Office of Controlled Substances Administration to enter and inspect”.

A separate state controlled-substance registration requirement was also not read.

Maryland APRN certification expires on the same date as the holder's RN licence and renews in 2-year terms, and the Board may not renew an APRN whose current national certification by a recognized certifying body is not on file.

An APRN who qualifies through a Nurse Licensure Compact multistate privilege must ensure at all times that the Board holds current documentation of that national certification, and that route's certification term is 2 years, expiring on the 28th day of the birth month in an odd- or even-numbered year matching the parity of the licensee's birth year.

Federally, a PMHNP registers with the DEA as a mid-level practitioner, and that registration covers only what Maryland allows.

The DEA/HHS telemedicine flexibilities — extended through December 31, 2026 — remove the federal in-person-visit requirement for remote controlled-substance prescribing; they lift no Maryland rule.

Maryland has not enacted the APRN Compact — it is not among the five states that had enacted it as of September 2026 (Delaware, North Dakota, South Dakota, Utah and Wyoming) — and the compact takes effect only once 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 in another state, though § 8-302.1 does let an APRN applicant qualify with either a Maryland RN licence or such a multistate privilege for the underlying registered-nurse layer.

To practise as a PMHNP in Maryland you need Maryland certification through the Board of Nursing.

No 2023–2026 amendment to the rules this page rests on appears in the sources read: the same 18-month mentor figure appears in Health Occ. § 8-302.1(d)(1) and in COMAR's current definition, and no newer text appears in them.

The dated item that moves is AANP's, not Maryland's: its November 2025 snapshot lists Maryland on the time-in-practice list and its May 2026 map carries the Full label.

Confirm the current text with the Maryland Board of Nursing and the General Assembly before assuming the rules are unchanged — the sources were read on September 24, 2026.