Nurse Practitioners Could Lose Full Practice Authority as COVID Order Expires in NJ
- New Jersey's COVID-era practice waivers for approximately 17,000 APNs expire at 5 p.m. on April 2, 2026, requiring all APNs to have joint protocols with collaborating physicians in place or risk losing prescriptive authority.
- Clinics, medical spas, independent practices, and surgery centers opened or expanded under the waiver face potential closure, restructuring, or significant new costs if compliance is not achieved in time.
- Senate Bill 2996, introduced January 13, 2026, would grant full practice authority to APNs with at least 24 months or 2,400 hours of experience, but remains in committee with no guarantee of passage before the deadline
- The bill's own text notes that over 45 percent of NJ APNs practiced without restrictions under the waiver, and that no adverse incidents were reported during that period.
For nearly six years, thousands of New Jersey advanced practice nurses built practices, expanded access to care, and filled critical gaps in the state's healthcare system without a collaborating physician looking over their shoulder. That era ends at 5 p.m. on April 2, 2026.
What started as a pandemic emergency measure has become the foundation of how many NJ nurse practitioners, nurse anesthetists, and other APNs practice day to day. Now, with a hard deadline just days away and a full practice authority bill still sitting in committee, the state's approximately 17,000 APNs are facing a stark choice: secure a collaborating physician, pay what critics call a "supervision tax," or close up shop.
How NJ APNs Got Here
The story starts in March 2020. When former Governor Phil Murphy declared a COVID-19 State of Emergency, he subsequently issued Executive Order 112, which suspended the requirement that APNs enter into joint protocols with collaborating physicians in order to prescribe medications and medical devices. The intent was to rapidly expand healthcare capacity during the crisis. What followed was nearly six years of de facto autonomy for New Jersey APNs.
In that time, APNs opened independent practices in primary care, psychiatry, palliative care, aesthetics, and more. They served patients in underserved communities where physician access was limited. They hired staff, signed leases, and invested in their practices under the assumption that the regulatory landscape would continue to evolve in their favor.
Then, four days before leaving office, Governor Murphy signed Executive Order 415, officially ending the State of Emergency and revoking the waivers effective February 16, 2026. The window to comply was originally just 30 days. Advocates immediately pushed back, warning that the timeline was impossible and the consequences would be severe.
On February 13, newly inaugurated Governor Mikie Sherrill signed Executive Order 13, buying APNs an additional 45 days. "These sudden regulatory changes will have wide-ranging impacts on health care professionals and patients alike, potentially even forcing clinics and small, independent practices to close their doors, making it more difficult for New Jerseyans to access critical health care services," Sherrill said at the time.
That extension expires April 2.
What Is at Stake
The scale of the problem is significant. Legal experts at Fox Rothschild note that approximately 17,000 APNs and 4,000 physician assistants in New Jersey have been practicing under the suspended requirements since 2020. Finding a collaborating physician willing to enter into a joint protocol is not simple or cheap. In many markets, collaborating physicians charge substantial monthly fees for their signatures, sometimes thousands of dollars per month, even when they have no direct involvement in patient care.
The practices most at risk are those that rely entirely on APN prescriptive authority: independent primary care clinics, psychiatric practices, palliative care providers, and medical spas. NJBIZ reported that state officials specifically flagged added pressure on medical spas, surgery centers, and small independent practices. If an APN cannot secure a collaborating physician in time, they lose the ability to prescribe medications or order medical devices, which for many practice types means the doors close.
The whiplash is particularly sharp for APNs who were encouraged to step up during COVID and then built their entire professional model around the autonomy that followed. Many APNs employed by large health systems never benefited from the waiver at all, as internal hospital policies kept collaboration requirements in place even when state law did not require them. That fragmented reality means the impact of the deadline is uneven: independent APN owners bear the full burden, while system-employed APNs largely continue as before.
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The Bill That Could Change Everything
There is a legislative path out. Senate Bill 2996, introduced January 13, 2026, by Senator Joseph Vitale and a broad bipartisan coalition, would permanently eliminate joint protocol requirements for APNs who have completed at least 24 months or 2,400 hours of licensed, active advanced nursing practice. APN-Anesthesia providers meeting the same threshold would be authorized to practice without the physician supervision requirements entirely.
The bill's legislative findings include a notable data point: over 45 percent of NJ APNs practiced without restrictions during the waiver period, and no adverse incidents were reported. That record is central to advocates' argument that collaboration requirements are a regulatory burden rather than a patient safety measure.
The bill was heard in the Senate Health, Human Services and Senior Citizens Committee on February 9, 2026. As of publication, it remains in committee. Healthcare law firm Frier Levitt has noted that Governor Sherrill's language in EO 13 signals a potential willingness to sign the bill if it reaches her desk, though that outcome is far from guaranteed before the April 2 deadline.
If S2996 does not pass before the waiver expires, APNs will be required to comply with pre-pandemic law immediately. A future passage would not retroactively protect any APN who loses prescriptive authority in the interim.
What NJ APNs Need to Do Now
Whether or not S2996 passes, compliance with current law is required by April 2. APN-NJ, the state's advanced practice nurse association, is actively providing guidance and sharing information about collaboration options to support members during the transition.
APNs should take the following steps now:
- Know your status. If you are employed by a health system, confirm whether your employer already has joint protocols in place. If you operate an independent practice, assume you must secure a collaborating physician unless you receive confirmed legal guidance otherwise.
- Start the search immediately. Finding a collaborating physician who will enter into a formal joint protocol takes time. Healthcare law firms that specialize in APN practice structures, including the management services organization model, can help navigate options if a physician collaborator is not available.
- Engage in advocacy. The outcome of S2996 is not yet decided. APNs, patients, and practice owners can contact their state legislators directly, attend hearings, and share the real-world impact of the waiver expiration on their practices and patient populations. The New Jersey legislature needs to hear concrete stories about what is at stake.
- Document everything. If your practice is forced to restructure or reduce services because of the waiver expiration, document the impact. That record may matter for future advocacy and for any potential legal or regulatory proceedings.
The question now is whether New Jersey will codify what APNs built during COVID, or force them to dismantle it under deadline pressure. The answer may arrive before April 2. It may not.
Nurses, what do you think? Share your thoughts in the discussion forum below.
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