Wisconsin Shifts from APNPs to APRNs: What APNPs, RNs, and Employers Should Know
Beginning September 1, 2026, Wisconsin will no longer certify Advance Practice Nurse Prescribers (APNPs). Instead, Wisconsin will license Advanced Practice Registered Nurses (APRNs). For current APNPs and their employers, the biggest practical issue is making sure you understand the new application requirements and are prepared before the September 1 deadline.
This article covers:
- What is changing regarding APNP certification and APRN licensure,
- When collaboration agreements are required,
- What is needed for independent practice;
- What APNPs should be prepared to do; and
- What employers or solo practice APNPs should be prepared to do.
If you’d like assistance, please reach out to lzimmer@mccarty-law.com, criordan@mccarty-law.com, or contact us on our website contact form.
Effective September 1, 2026, Wisconsin will shift away from certifying APNPs and will instead license APRNs. This shift stems from 2025 WI Act 17, also known as the APRN Modernization Act. This is a substantial shift from the nursing laws and regulations that have been in effect since the 1990s.
The Wisconsin Board of Nursing (the Board) issued an order adopting emergency rules that repealed, amended, created, and recreated sections of Chapter N8, the administrative code governing the certification of APNPs (the Emergency Rule). The Emergency Rule will be in effect for either two years or until a permanent rule takes effect, whichever happens first.
The Emergency Rule alters Chapter N8 to provide for the licensure of APRNs. All APRNs must have a certification in a “recognized role.” The recognized roles are:
(1) certified nurse midwife,
(2) certified nurse specialist,
(3) nurse practitioner, and
(4) certified registered nurse anesthetist.
All licenses will specify the recognized role held by the APRN (ex: an APRN in the role of certified nurse specialist will have the license of APRN-CNS).
We expect bumps in the road as the Emergency Rule comes into effect. As such, prepare for delays, hiccups, and some uncertainty throughout the application process.
What’s changed?
A lot, but also not as much as you may think. Yes, Wisconsin is shifting to licensing APRNs, but many requirements to be an APRN are the same as the previous requirements for APNP licensure.
What do I need to be an APRN with prescriptive authority?
An applicant must submit an application, pay the application fee, and provide evidence of:
- One of the following:
- A current Wisconsin RN license,
- A concurrent application to become a Wisconsin RN, or
- A multistate license from a state that has adopted the nurse licensure compact;
- Completion of a master’s or doctoral degree in nursing from a body approved by the Board;
- Current certification in at least one of the four recognized roles;
- Malpractice insurance coverage;
- No arrest or conviction record;
- Completion of 45+ contact hours in clinical pharmacology or therapeutics in the five years prior to the application date; and
- Passing the jurisprudence exam for APRNs.
How is this different than an APNP license?
The requirements above are substantially the same as the requirements needed for APNPs. The main differences are:
(1) someone applying to be an RN can concurrently apply to be an APRN,
(2) an APRN (or an APRN’s employer) must now provide proof of malpractice insurance, and
(3) an APRN must show proof that the APRN has no arrest or conviction record.
Certified nurse midwives, specifically, must meet all the above requirements and file a proactive plan with the Board if the CNM will assist with deliveries outside of a hospital setting. This plan must include (1) the hospital or facility where a patient and newborn will go in case of emergency; (2) the method and protocol for emergency transport; and (3) protocol for transfer of prenatal and intrapartum medical records and current medical conditions. However, by filing the proactive plan, the CNM may practice without a collaboration agreement.
Nonetheless, we are expecting that APNPs will keep the same license number upon application for APRN. This should, hopefully, mitigate insurance and payer issues. CNMs, however, will become APRN-CNMs and will receive a new license number.
Collaboration Agreements
Unfortunately, APRNs must initially still practice with a documented, written collaboration agreement in place. However, upon meeting certain requirements, discussed below, the APRN can apply for independent practice.
Independent Practice
Applying for independent practice is a new legal concept that is separate from an APRN owning and running a business (a solo practice). Once an APRN has applied for and received approval, independent practice allows an APRN to practice in the absence of a collaboration agreement. The independent practice APRN is still expected to refer out or seek collaboration to address a condition or issue outside their expertise.
To qualify for independent practice, an APRN must meet all of the following:
- Have provided 3,840 hours of professional nursing in a clinical setting with at least 24 months passing since the nurse began completing the clinical hours.
- Have provided 3,840 hours of clinical hours of advanced practice registered nursing practice in a recognized role, while under a valid collaboration agreement with a physician or dentist, with at least 24 months passing since the APRN began such practice in such recognized role.
In other words, an APRN must have 3,840 hours as an RN in a clinical setting and 3,840 hours as an APRN (under a collaboration agreement), all completed within at least the last 2 years, to apply for independent practice. An APRN may substitute extra APRN hours (under a collaboration agreement) to meet the requirements for the RN hours.
An APRN who is practicing independently must also contribute to the Injured Patients and Families Compensation Fund (IPFCF, or the Fund). (APRNs who are not going to take advantage of independent practice may not need to contribute to the Fund.)
Finally, the application for independent practice must be signed by someone who can attest that the applicant has met the above hour requirements, most likely a medical director, dean, or supervising physician/dentist. As of right now, we do not know what, exactly, this attestation will look like or what information it will require.
Though independent practice is an option for some APRNs, it is likely that insurers, payers, the Fund, and employers (if applicable) will require some form of collaboration agreement in place. For example, Medicare may likely continue to require a collaboration agreement for most APRNs to bill for services.
It may be wise to wait before taking any action on a collaboration agreement.
I’m currently an APNP. What should I do?
- There is no need to renew your APNP certification, since the certification is going away entirely in Wisconsin starting September 1, 2026.
- Watch for DSPS to release information regarding applications, information, and types of evidence needed for the APRN license, but keep in mind this information is subject to change.
- Find or request proof of your certificate in your recognized role or other specialty. There is likely to be a wave of requests from other APNPs and RNs in a similar situation. It may be best to get this out of the way sooner rather than later.
- The APRN application is expected to be available for submission on August 1, 2026. We recommend preparing and submitting your application as soon as possible to ensure you are licensed by September 1. The guidelines state that DSPS will respond to applications within 10 days of filing, but it is unclear whether DSPS will be able to meet that timeline given the volume of requests it will receive. It is also unclear what could happen if an application is not processed or approved by that deadline.
I’m an employer or solo practice APNP, what should I do?
- Make sure your APNPs are aware of this change. Instruct them to find or request proof of their certificate in their recognized role or other specialty.
- Inform your malpractice insurance that this legislative change is coming. They should, hopefully, be aware, but it is best to confirm that coverage will continue as expected.
- Review employment agreements and organizational documents and update them to reflect the shift away from the APNP title.
- If you are confused, uncertain, or receiving questions you don’t know how to answer, please reach out to legal counsel.
This is likely to be a confusing and bumpy road as Wisconsin makes the shift from APNPs to APRNs. Our health law attorneys at McCarty Law are here to help. If you’d like assistance, please reach out to lzimmer@mccarty-law.com, criordan@mccarty-law.com, or contact us on our website contact form.
Caitlin Riordan
Caitlin is a member of the Business section at McCarty Law where she works on entity formation, commercial transactions, and contract review. She has additional interest in appellate practice and intellectual property but also loves learning new fields of law.