Wisconsin’s APRN Modernization Act: Key Changes for Advanced Practice Nurse Prescribers and Their Employers

On August 7, 2025, the Wisconsin State Legislature passed Assembly Bill 257, known as the “APRN Modernization Act.” This legislation, approved by Governor Evers, creates a new advanced nursing licensure category for “advanced practice registered nurses” (“APRNs”) and, for the first time, allows qualifying APRNs to practice independently without the need for a collaborative practice agreement with a physician. The new law is set to take effect on September 1, 2026.

Prior to this bill, Wisconsin law provided for the certification of “advanced practice nurse prescribers” (“APNPs”). APNPs were required to enter into collaborative arrangements with physicians, ensuring that the APNP had access to a physician for consultation and referral as needed. Under the new law, the Wisconsin Board of Nursing is directed to issue a separate license for advanced practice nurses, retitled APRN. The bill recognizes four APRN roles: (1) nurse practitioner; (2) certified nurse-midwife; (3) certified registered nurse anesthetist; and (4) clinical nurse specialist. The APRN must have a current national certification in their recognized role (“Recognized Role”).

Unlike the previous APNP certification, APRNs are permitted to practice independently, without a collaborative agreement with a physician or dentist, after the following requirements are met:

1. The APRN has completed at least 3,840 clinical hours of advanced practice registered nursing in their Recognized Role, with a physician or dentist who is “immediately available for consultation” and accepted responsibility for the APRN’s actions during those hours; and
2. At least 24 months must have elapsed since the APRN began practicing in the Recognized Role.

Until both conditions are met, the APRN is required to practice under a collaborative agreement.

The new law requires APRNs to maintain malpractice insurance coverage at levels not less than those established for participation in the Injured Patients and Families Compensation Fund (“IPFCF”), and requires APRNs to pay directly into the IPFCF, aligning their obligations with those of physicians and certified registered nurse anesthetists.

It is important to note that this bill only changes state law certification requirements in the Wisconsin Nursing Act with respect to the scope of practice of advanced nursing practitioners. APRNs, their employers or group practices (“APRN Practices”) must continue to comply with payor coverage and billing/payment requirements. For example, APRN Practices must comply with Medicare’s conditions of coverage and payment and State Medicaid coverage and billing regulations and guidelines. Accordingly, consideration of state, federal and even private payor contracts is needed to ensure that the services currently being provided by APNPs/APRNs pursuant to a collaborative agreement are billable services without the agreement in place.

Additionally, the new law does not prohibit a practice or medical staff committees from requiring that an APRN enter into a collaborative agreement or other consultation with a physician as a condition of obtaining/maintaining privileges. While such a requirement could impact the hospital’s/practices’ ability to obtain/retain top nursing talent, such oversight is an option for policy continuity purposes.

Practical Takeaways

• Review Clinical Hours: Employers must carefully review the number of clinical hours and months of practice that newly-licensed APRNs have completed before terminating collaborative agreements.
• Monitor Rulemaking: Stay current with any new continuing education or practice requirements promulgated by the Wisconsin Board of Nursing.
• Assess Insurance: Ensure that APRNs have appropriate malpractice insurance coverage and are participating in the IPFCF as required.
• Update Medical Staff Governance (and Employment) Documents: Bylaws, Rules & Regulations, policies, privilege cards, application forms, etc., may need to be updated to use the new title and address changes to the scope of practice for APRNs; job descriptions and employment contracts may require amending; and collaborative practice agreements may need to be amended or terminated.
• Review Billing Policies: Stay alert for further federal or state regulatory updates, especially regarding billing and reimbursement, and review payor contracts to ensure compliance.

For further information or assistance regarding this topic, please contact:

• Robin Sheridan at (414) 721-0469 or rsheridan@hallrender.com;
• Lori Wink at (414) 721-0456 or lwink@hallrender.com
• Ben Lockwood at (414) 721-0484 or blockwood@hallrender.com; or
• Your primary Hall Render contact.