Georgia Medical Board Addresses Questions Regarding APRN Protocol Agreements

Former President of United Advanced Practice Registered Nurses of Georgia presenting a statement at June 4, 2026 meeting of the Georgia Composite Medical Board

The healthcare community has been closely watching developments involving the Georgia Composite Medical Board's interpretation of state laws governing Advanced Practice Registered Nurses (APRNs) who own or operate their own practices.

On May 9, 2026, the Medical Board issued a position statement addressing physician supervision and protocol requirements for APRNs and physician assistants. In it, the Board emphasized the legal requirement for APRN practices to have physician supervision. It went on to state that using a third-party service to connect APRNs with supervising physicians will not, by itself, resolve compliance concerns, and that Georgia law prohibits "a physician receiving compensation of any kind, monetary or non-monetary, from an APRN or an APRN-owned company in exchange for serving as the supervising or delegating physician." Because third-party physician matching companies and paid physician supervision arrangements are common in Georgia APRN-owned practices, many viewed the statement as a threat to their existing business models. The United Advanced Practice Registered Nurses of Georgia (UAPRN) posted that the Board’s statement posed “an immediate and serious risk to patient access to care across the state.” These concerns prompted many inquiries to the Board and even a protest organized by healthcare professionals at Liberty Square in downtown Atlanta, with the Board’s June 4th meeting being heavily attended by leaders in the medical community.

On June 5, 2026, the Medical Board released another statement and a follow-up document addressing what it described as "misinformation" surrounding these issues. The Board clarified that it is not requiring APRNs to close their practices or terminate existing protocol agreements. Instead, the Board maintains that its May statement only reflects its longstanding interpretation of Georgia law and was issued in response to an increasing number of questions and protocol applications that raised compliance concerns.

The Board’s clarification statement goes on to say that moving forward, it intends to closely examine physician-APRN relationships when reviewing protocol agreements to ensure independent medical judgment and a genuinely collaborative relationship between supervising physicians and advanced practice providers. Questions remain regarding how the Board’s interpretations will affect APRN practice structures, supervision arrangements, and future protocol approvals. The statement concludes with the Board acknowledging that discussions with stakeholders are ongoing and that additional guidance may be forthcoming as it works with the Georgia Boards of Nursing and Pharmacy to address these issues.

This article is provided for informational purposes only and does not constitute legal advice.

Georgia Supreme Court Recognizes Alternative Licensing Certification for Lactation Care Providers

In a recent decision, the Georgia Supreme Court held that the State Constitution protects Georgians’ right to pursue an occupation of their choosing free from unreasonable government interference. The case directly concerned the rights of lactation care providers (LCs) to practice with alternative licensing credentials, though it could potentially have a far-reaching impact on other professionally licensed occupations in Georgia.

In Jackson, et al. v. Raffensperger, Plaintiffs Mary Jackson and her non-profit lactation consulting organization, Reaching Our Sisters Everywhere, Inc. (“ROSE”) filed a lawsuit against the Secretary of State challenging the constitutionality of the Georgia Lactation Consultant Practice Act (the “Act”), which prohibits the practice of “lactation care and services” for compensation without a license from the Secretary of State. Plaintiffs alleged that under the Act, they were not eligible for a license because they lacked a privately issued credential that the Act requires for licensure, even though they had other private credentials that made them equally competent to provide lactation care and services to the public. Plaintiffs argued that the Act violated their constitutional rights.

On Appeal, the Georgia Supreme Court recognized that LCs – like other practitioners in the healthcare field – can obtain certification from multiple private accrediting entities. Here, the Court found that the two most prominent certifications are Certified Lactation Counselor (“CLC”), which Jackson and many members of ROSE had, and International Board-Certified Lactation Consultant (“IBCLC”). While there were significant differences in the credentialing requirements between CLC and IBCLC, the Court recognized that CLCs and IBCLCs are equally competent to provide lactation care and services to mothers and babies and there was no evidence that CLCs or other unlicensed LCs have ever harmed public health, safety, or welfare. Nonetheless, the Act only permitted IBCLCs to be licensed by the State. The Court noted that discrepancy and found it to be an unreasonable government interference on LCs to pursue their occupation.

Continuing its analysis, the Court found held that the Georgia Constitution affirmatively protects an individual’s right to pursue the lawful occupation of her choosing free from unreasonable government interference.

While this case exclusively concerned lactation care providers, Georgia’s licensed healthcare and other professionals should be aware that the Court’s holding could potentially be used to challenge the State’s licensing protocols in other professions. Provided that practitioners can show that the alternative licensing entity is as meritorious and safe as State-approved licensing entity, those practitioners may also have a path to valid licensure by the State.

Georgia’s Professional Licensing Boards Approve Temporary Practice Permits for Healthcare Providers in Response to COVID-19 Pandemic

In response to the public health emergency posed by the novel coronavirus, several of Georgia’s licensing boards have been authorized to issue “emergency practice permits” allowing healthcare professionals to practice in Georgia for a limited amount of time. Interested healthcare professionals are encouraged to review the following information and to contact their respective licensing boards as indicated below. Our team of lawyers at Levy Pruett Cullen is working remotely and monitoring the rapidly evolving pandemic.  Please check our website for updates and call with any questions: 404-371-8857.

Georgia Composite Medical Board 

Following the Governor’s March 14th declaration of a public health emergency, the Georgia Composite Medical Board may approve and issue “emergency practice permits” to physicians, physician assistants, advanced practice registered nurses, and respiratory care professionals who wish to practice medicine in Georgia during the current COVID-19crisis.

Before practicing medicine in Georgia pursuant to an emergency practice permit, the applicant must receive the Board’s approval of the following:

• An application for an emergency practice permit (see link below).

• Proof of current and unrestricted licensure in another state.

• Copy of a valid government-issued photo ID, and

• A current National Practitioner’s Data Bank Report.

All permits issued under this provision shall be valid for 90 days or until the state of emergency has been lifted by Georgia’s governor, whichever comes first.

Information for submitting an application, as well as the permit application itself, is available at https://medicalboard.georgia.gov/press-releases/2020-03-16/gcmb-emergency-practice-permittemp-license-response-covid-19.

Georgia Board of Nursing

Following the Governor’s March 14th declaration of a public health emergency, the Georgia Board of Nursing is authorized to issue temporary permits to licensed practical nurses, registered nurses, and advanced practice registered nurses who have an active, unencumbered license in any other U.S. jurisdiction who are coming to Georgia to respond to the COVID-19 pandemic. 

Temporary permits issued by the Georgia Board of Nursing are valid for 30 days, though the Board is authorized to extend the expiration date. This policy is effective while a State of Emergency, as declared by the Governor, exists in any Georgia county or until rescinded by the Board, whichever occurs first. Application fees for the temporary permit are waived for those applying to practice in response to the COVID-19 emergency.

Additional information and the permit application are available at https://sos.ga.gov/index.php/licensing/plb/45/emergency_temporary_permits.

Finally, Georgia is a member of the Nurse Licensure Compact, which allows licensed practical nurses and registered nurses with a multi-state license from another Compact jurisdiction to practice in Georgia.  

Georgia Board of Pharmacy

Following the Governor’s March 14th declaration of a public health emergency, the Georgia Board of Pharmacy is authorized to issue temporary licenses to dispense prescription drugs for pharmacists who are not licensed in Georgia but are currently licensed in another state. A temporary license may be issued if (1) the Board can verify the applicant’s current licensure is in good standing with the state or indirectly via a third-party verification system and (2) the applicant is engaged in a documented COVID-19 relief effort. 

The Board is also authorized to issue temporary licenses for pharmacy technicians and pharmacy interns to assist pharmacists in dispensing prescription drugs in response to the COVID-19 emergency. Pharmacy technicians and pharmacy interns applying must also be currently registered or licensed in good standing in another state.

The temporary recognition of non-resident pharmacist licensure and pharmacy intern licensure shall remain valid until the end of the month following the third board meeting conducted after the license is issued and shall not be renewed. The temporary recognition of non-resident pharmacy technician registration shall cease when the state of emergency is lifted. 

Additional information from the Georgia Board of Pharmacy and permit applications are available at https://gbp.georgia.gov/press-releases/2020-03-17/covid-19-coronavirus-response-georgia-board-pharmacy.

Are You a Nurse with a Licensing Board Case and Administrative Action?

I'm Frances Cullen. If you're a nurse with a licensing board case, an administrative action, or a criminal action, we have 25 years of experience we will bring to bear in providing you with the best legal representation possible for your case.

Levy Pruett Cullen is a law firm dedicated to the defense of licensed professionals. We have extensive experience in representing numerous healthcare professionals with issues before professional licensing boards, before professional review agencies, and obtaining licensure in the state of Georgia.

We also provide representation for all types of criminal cases, any of which could impact your ability to practice your profession.

It is important to have an attorney on your side that is knowledgeable regarding the full scope of potential issues that could affect a licensee, and we'll pay particularized attention to the facts of your case.

Determining a defense to any licensing or criminal action, we will consider the various collateral consequences to figure out the best possible outcome.

The successful resolution of each case can vary for every client. Some individuals will spare obtaining the best possible result if they can obtain a speedy case resolution. Others can bear the emotional toll of working through case slowly but want to fight for the best result possible.

We listen to you and we pay attention to your needs.

For applicants, we are knowledgeable regarding each licensing board's requirements and can assist you in obtaining your professional license. If you are faced with an issue with a lapsed license, we can help you with the reinstatement of your license. We are familiar with all of the different licensing laws, regulations, and the collateral consequences that attached to a licensee.

At Levy Pruett Cullen, we can help you with your licensing case, administrative issues, civil cases, and criminal matters to reach the best possible resolution.

Are You a Chiropractor with a Licensing Issue or a Criminal Matter?

If you're a chiropractor with a licensing board issue or a criminal matter, we have more than 25 years of experience that we will bring to bear when providing you with the best legal representation possible for your case.

Levy Preutt Cullen is a law firm dedicated to the defense of licensed professionals with extensive experience in representing numerous health care professionals with issues before a professional licensing boards and review agencies, as well as obtaining licensure in the state of Georgia. We also provide representation for all types of criminal cases, any of which could impact your ability to practice your profession.

It's important to have an attorney on your side that is knowledgeable regarding the full scope of potential issues that could affect a licensee. We'll pay particularized attention to the facts of your case.

Determining defense to any licensing or criminal action, we will consider the various collateral consequences to figure out the best possible outcome.

A successful resolution of each case can vary for every client. Some individuals will spare, obtaining the best possible result if they can obtain a speedy case resolution. Others will choose to bear the emotional toll of working through a case slowly seeking the best result possible.

We will listen to you and pay attention to your needs.

For professional license applicants, we are knowledgeable regarding each licensing boards requirements and can assist you in obtaining your professional license.

If you are faced with an issue with a lapsed license, we can help you with the reinstatement of your license. We are familiar with all of the different licensing laws, regulations and the collateral consequences that attach to a licensee.

At Levy Pruett Cullen, we can help you with your licensing case, civil case, license application, or criminal matter to reach the best possible resolution.

Are You a Psychologist with a Licensing Case and Administrative Issue?

If you are a psychologist with a licensing board case, an administrative issue, or a criminal matter, we will bring 25 years of experience to bear when providing you the best legal representation possible for your case.

Levy Pruett Cullen is a law firm dedicated to the defense of licensed professionals with extensive experience in representing numerous healthcare professionals with issues before professional licensing boards and professional review agencies, as well as obtaining licensure in the state of Georgia. We also provide representation for all types of criminal cases, any of which could impact your ability to practice your profession.

It is important to have an attorney on your side that is knowledgeable regarding the full scope of potential issues that could have set a licensee and we pay particularized attention to the facts of your case.

Determining defense to any licensing or criminal action, we will consider the various collateral consequences to figure out the best possible outcome.

The successful resolution of each case can vary for every client. Some individuals will spare obtaining the best possible result if they could obtain a speedy case resolution. Others can bear the emotional toll of working through a case slowly but want to fight for the best result possible.

We'll listen to you and pay attention to your needs.

For applicants, we are knowledgeable regarding each licensing boards requirements and can assist you in obtaining your professional license. If you are faced with an issue with a lapsed license, we can help you with the reinstatement of your license. We are familiar with all of the different licensing laws, regulations, and the collateral consequences that are attached to a licensee.

At Levy Pruett Cullen we can help you with your license case, administrative issues, civil cases, and criminal matters to reach the best possible resolution.

Are You a Pharmacist with a Licensing Board and Administrative Case?

I'm Frances Cullen. If you're a pharmacist with a licensing board, administrative action or criminal case. We have 25 years of experience. We will bring to bear in providing you with the best legal representation possible for your case.

Levy Pruett Cullen is a law firm dedicated to the defense of licensed professionals with extensive experience in representing numerous healthcare professionals with issues before professional licensing boards, before professional review agencies, and obtaining licensure in the state of Georgia. We also provide representation for all types of criminal cases, any of which could impact your ability to practice your profession.

It is important to have an attorney on your side that is knowledgeable regarding the full scope of potential issues that could have set a licensee and we pay particularized attention to the facts of your case.

Determining defense to any licensing or criminal action, we will consider the various collateral consequences to figure out the best possible outcome.

The successful resolution of each case can vary for every client. Some individuals will spare obtaining the best possible result if they could obtain a speedy case resolution. Others can bear the emotional toll of working through a case slowly but want to fight for the best result possible.

We'll listen to you and we'll pay attention to your needs.

For applicants, we are knowledgeable regarding each licensing boards requirements and can assist you in obtaining your professional license. If you are faced with an issue with a lapsed license, we can help you with the reinstatement of your license. We are familiar with all of the different licensing laws, regulations, and the collateral consequences that are attached to a licensee.

At Levy Pruett Cullen, we can help you with your license case, administrative issues, civil cases, and criminal matters to reach the best possible resolution.

Are You a Healthcare Professional with a Licensing Case?

I am Frances Cullen of Levy Pruett Cullen. We are a law firm dedicated to the defense of licensed professionals. We have extensive experience in representing numerous healthcare professional with issues before professional licensing boards, before professionals review agencies, and obtaining licensure in the State of Georgia. We also provide representation for all types of criminal cases, any of which could impact your ability to practice your profession.

It is important to have an attorney on your side that is knowledgeable regarding the full scope of potential issues that could affect a licensee. We pay particularized attention to the facts of your case. Determining defense to any licensing or criminal action, we will consider the various collateral consequences to figure out the best possible outcome.

A successful resolution of each case can vary for every client. Some individuals will spare obtaining the best possible result if they could obtain a speedy case resolution. Others can bear the emotional toll of working through a case slowly but want to fight for the best result possible. We listen to you and we pay attention to your needs.

For applicants, we are knowledgeable regarding each licensing board requirements and can assist you in obtaining your professional license. If you are faced with an issue, with a lapsed license, we can help you with the reinstatement of your license. We are familiar with all of the different licensing laws, regulations, and the collateral consequences that attach to a licensee.

We can help you with your licensing case, administrative issues, civil cases and criminal matters to reach the best possible resolution.

Are You a Physician Facing a Licensing Board Action or a Criminal Matter?

I'm Frances Cullen. If you're a physician facing a licensing board action, administrative issue or a criminal matter, Levy Pruett Cullen can leverage our more than 25 years of experience when providing you with the best legal representation possible for your case.

We are knowledgeable and experienced with the laws and rules regulating the practice of medicine and we are very well familiar with the Georgia Composite Medical Board. We therefore can guide you through a board investigative process and all of the issues you may be facing with the board matter. A board case begins with a complaint, followed by investigation, followed by board review. We know the Georgia Medical Board and were familiar with the other agencies that could take action against you. We understand the process and the potential way to resolve your case.

Are You a Healthcare Professional Seeking Licensure in Georgia?

At Levy Pruett Cullen, we have assisted numerous professionals in seeking licensure in the State of Georgia. We have represented physicians, dentists, pharmacists, nurses, psychologists, and many other health care professionals in seeking to attain a license to practice in the State, often successfully appealing a denial of licensure or assisting with initial submission of an application.

Often, applicants for licensure do not meet the requirements set forth for licensure in the State of Georgia for their particular profession, due to being educated in past years when the licensing requirements were different or their training was geared toward licensing in another state. Or an applicant may have a past criminal conviction or a licensing board case in another state that could affect or hinder their ability to gain a license here.

An applicant who does not meet the requirements set forth for licensure, who have something in their past that is potentially detrimental can still attain licensure. A careful assessment of an applicant's case and background is necessary to determine whether we could potentially overcome these issues and resolve the potential block to obtaining a license.

We understand and know the particular licensing boards and their demanding requirements. We've represented numerous applicants for licensure and helped bring the talents of many physicians, dentists, pharmacists, psychologists and nurses to the State of Georgia, and we are proud to have done so.

If you are seeking licensure in the State of Georgia and believe you may have any difficulty in obtaining your license or if you have applied for a license and been issued a denial letter by your respective licensing board, contact Levy Pruett Cullen. We may be able to work with you to help you achieve your goal of practicing your profession here in the State of Georgia.