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NP Full Practice Authority Texas: What the 2027 Session Could Change for NP-Owned Practices

Writer: Michael Madrinkian
Michael Madrinkian
4 days ago
9 min read

Updated: 1 day ago

The NP full practice authority Texas lawmakers considered in 2025 stalled in committee, so nurse practitioners still prescribe under a physician's prescriptive authority agreement. The Legislature returns January 12, 2027. The 2025 bills show the range of what could come back, and the narrowest would not reach DFW. Pre-Opening Advisory models both outcomes.


By Michael Madrinkian, MBA, PhD, Founder and Principal, Luminary Strategic



Status, last checked November 3, 2026: no 2027 bill had been filed. The first filing day for the 90th Legislature is November 9, 2026, and the session opens January 12, 2027. This post describes statutes and bills in general terms. It is not legal advice, and your attorney decides how any of it applies to your practice.


THE SHORT ANSWER


  • Texas still requires the physician link. A physician delegates prescribing to a nurse practitioner through a written prescriptive authority agreement.

  • Four sets of bills tried to change that in 2025. None left committee. They ranged from statewide independence with no hours test to a rural-only pathway after years of experience.

  • The version matters more than the headline. The narrow bill's county limit would have left Dallas, Tarrant, Collin, and Denton counties where they are today.

  • Ownership citations sat outside all of them. None of the 2025 bills amended the two Occupations Code sections usually cited on who may own a medical practice.

  • Plan for both outcomes. Keep the physician relationship in your budget and sign terms that can change if the law does.


WHERE NP FULL PRACTICE AUTHORITY TEXAS STANDS TODAY


Under Texas Occupations Code §157.0512, a physician may delegate prescribing or ordering a drug or device to an advanced practice registered nurse acting under adequate physician supervision, through a prescriptive authority agreement. Nurse practitioners are one kind of advanced practice registered nurse, a group that also includes nurse midwives, nurse anesthetists, and clinical nurse specialists.


Counts of states with full practice authority vary by source and date. CM&F Group, a professional liability insurer, put the figure at about 30 states plus Washington, D.C., in June 2026, and described it as "some form" of full practice authority. A Cato Institute witness told a Texas Senate committee in May 2025 that Texas trailed 30 other states. The American Association of Nurse Practitioners keeps the map most sources cite. Texas is outside every one of those counts.


This matters to a practice owner for a business reason. In many Texas med spas, the nurse practitioner's agreement and the medical director relationship are the same physician, so that one contract holds up the prescribing, the delegated services, and often the ownership structure. Any change in the law would touch only part of that stack.


PRESCRIPTIVE AUTHORITY AGREEMENT: WHAT TEXAS REQUIRES NOW


These are the requirements as written in §157.0512 and in the Texas Medical Board's delegation rules, as of November 2026. Ask your attorney which apply to your arrangement.


  • A written, signed agreement. It names the parties and their license numbers, the practice locations, the drugs or devices covered, a consultation and referral plan, a plan for patient emergencies, and how the two share information.

  • A quality plan with chart review. The physician and the nurse practitioner decide how many charts are reviewed.

  • Meetings at least once a month. They cover patient care, referrals, and care improvement, and they must be documented. The parties decide how the meetings take place.

  • Annual review. The agreement and any amendments are reviewed, dated, and signed at least once a year.

  • A limit on the physician. A physician may have agreements with no more than seven advanced practice registered nurses and physician assistants combined, or their full-time equivalent, with exceptions for medically underserved populations and hospital facility-based practice. HB 3749, known as Jenifer's Law, counts elective IV therapy agreements toward that limit.

  • Registration. Medical Board rule §169.5 has the delegating physician register the delegate, the start date, and the practice locations within 30 calendar days, and report termination within 30 calendar days. The Board keeps a searchable public list of these agreements.

  • Records. Each party keeps a copy until the second anniversary of the agreement's end. The agreement must be available to the licensing boards by the third business day after a request.


The statute sets no fee. What a physician charges for this work is a private term, which is why published figures vary so widely and why the 2025 bills raised it, as the next section shows.


Your med spa compliance records should show each of these items on a date. The med spa compliance binder lists what an owner should be able to produce.


WHAT THE 2025 BILLS WOULD HAVE DONE


The table above compares the introduced text of each bill. Three designs emerged.


The broad version


HB 3794 and its identical Senate companion, SB 1859, had the Texas Board of Nursing authorize independent practice on application, with no hours requirement in the bill text. They included prescribing of Schedule II through V controlled substances. HB 1756 took a similar broad approach. The House Public Health Committee heard HB 3794 for a full day on April 14, 2025. The Texas Medical Association called stopping scope expansion its top priority that session. Supporters argued the bill would remove outdated barriers and costly delegation agreements. The committee left it pending.


The experience-based version


SB 911, the HEAL Texans Act, set a threshold of 3,000 clinical practice hours within the prior five years and stopped at Schedule III through V. It was referred to the Senate Business and Commerce Committee on February 13, 2025, and went no further.


The rural version


SB 3055 came late, with permission to introduce on April 22, 2025. It required 10 years or 20,000 hours of licensed practice, or four years or 8,000 hours under a prescriptive authority agreement after a Texas program with in-person clinical work. It then limited independent practice to counties with fewer than 68,750 residents. Dallas, Tarrant, Collin, and Denton counties are each many times that size, so a nurse practitioner practicing in them would have kept the agreement.


SB 3055 also carried two provisions that could return on their own. It raised the physician's limit from seven to nine, though it left the full-time-equivalent wording at seven. It also required physicians to report any fee charged for a delegation agreement to the Medical Board each January, with the Board publishing the totals in anonymous form. We found no public data on these fees today, so that would have been the first. The Senate State Affairs Committee heard it May 1, 2025, and left it pending.


WHAT NONE OF THE 2025 BILLS TOUCHED


The NP full practice authority Texas owners ask about is often really an ownership question. We searched the introduced text of all five bills for the sections below.



Ownership. Occupations Code §155.001 bars practicing medicine without a license, and §164.052(a)(17) bars physicians from aiding unlicensed practice. Those provisions are why many practices with non-physician owners pair a physician-owned practice entity with a management company. None of the five bills cites either section. Whether a nurse practitioner practicing independently could hold a practice directly, and what would become of an existing management structure, are questions for your attorney. A bill passing would not answer them by itself.


Delegation to registered nurses. Many med spas rely on registered nurses for injectables, under physician delegation and the Medical Board's rules at 22 Texas Administrative Code §§169.25 to 169.28. The bills would have let an independent advanced practice registered nurse delegate and assign therapeutic measures to "assistive personnel." Whether that language reaches a registered nurse performing a cosmetic injection is a question the text does not settle.


Elective IV therapy. Jenifer's Law created Occupations Code Chapter 172, effective September 1, 2025, built on physician delegation of prescribing and administration. All five bills were written before it took effect and none refers to it. A 2027 bill would need to address that chapter for an IV line to change.


Laser hair removal. Three of the bills would have extended the Health and Safety Code §401.504 exemption to advanced practice registered nurses authorized to prescribe. That is the rare med spa line where the bill text speaks directly to the service.


Which of these questions apply to your practice depends on how it is built. Texas med spa regulations covers the wider framework.


HOW TO PLAN THE BUSINESS WITHOUT BETTING ON THE SESSION


Each of the 2025 bills carried a September 1 effective date in the session's year, and each gave the Board of Nursing until the following February 1 for rules. A 2027 bill on the same pattern would not change daily operations until late 2027 or early 2028, and it could arrive with a county limit, an hours test, or both.


  1. Budget the physician relationship in every scenario. Suppose a practice pays $2,500 a month for its prescriptive authority and medical director arrangement, a hypothetical figure. Full independence would not remove that whole $30,000 a year if registered nurses, IV services, or the ownership structure still depend on a physician.

  2. Check the term of your physician agreement. Ask your attorney how a change in law would affect the term, the fee, and the notice period.

  3. Do not sign a lease or a loan on the assumption of independence. A practice that works only if a bill passes has a thin plan.

  4. Track the experience thresholds. If your nurse practitioners are near the hours in SB 911 or SB 3055, keep dated records of practice hours under an agreement. Ask your attorney what would count.

  5. Watch the session's calendar. Texas Legislature Online shows each bill's filing, referral, and hearing. Luminary will update this post when a practice authority bill is filed and again after its committee hearing.


Founders opening their first location get the most from this kind of scenario work. How to open a med spa in Texas sets out the decisions in order.


WHAT THIS PLANNING COSTS


The Business Plan Review tests a Texas opening plan, including its physician costs, from $5,000. Pre-Opening Advisory carries the plan through opening, from $12,500. Both are for Texas practices. An operating owner weighing a change in structure or supervision uses the Advisory Engagement, from $15,000, through its Compliance Operations and Risk focus area. Luminary is a firm of medical spa consultants. It takes no compensation from device makers, distributors, lenders, or software vendors. How Luminary stays independent. Luminary does not give legal advice or draft agreements.


FREQUENTLY ASKED QUESTIONS


Do nurse practitioners have full practice authority in Texas?


No, as of the date checked above. A nurse practitioner in Texas prescribes through a prescriptive authority agreement with a physician, under Occupations Code §157.0512. Check the status line at the top of this post for the latest bill activity.


Can a nurse practitioner own a med spa in Texas?


Texas generally limits ownership of a medical practice to physicians, which is why many NP-owned med spas operate through two entities: a physician-owned practice and a management company the owner holds. Your attorney confirms what fits your situation.


How many nurse practitioners can one physician supervise in Texas?


The statute limits a physician to prescriptive authority agreements with seven advanced practice registered nurses and physician assistants combined, or their full-time equivalent. Exceptions apply to practices serving medically underserved populations and hospital facility-based practice.


Does a prescriptive authority agreement have to be filed with the state?


Medical Board rules have the delegating physician register the delegate, the start date, and the locations within 30 calendar days. The agreement itself must be made available to the boards by the third business day after a request.


If a bill passes in 2027, when would it take effect?


That depends on the bill. Each 2025 version set a September 1 effective date in the session's year and a rule deadline the following February 1. A 2027 bill could follow that pattern or set its own dates.


REQUEST A SCOPING CALL


Luminary works with med spa and wellness practice owners in person across Dallas-Fort Worth and virtually nationwide; Pre-Opening Advisory is for practices opening in Texas. A scoping call is 30 minutes and confirms which engagement fits. Request a scoping call or call 469-894-8793.


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