Wisconsin APRNs Gain Independence, Medicare Billing Unclear

Wisconsin’s advanced practice registered nurses (APRNs) can now practice independently without a physician’s oversight, thanks to the APRN Modernization Act, 2025 Wisconsin Act 17. The law, which took effect on September 1, allows APRNs to see patients on their own, but uncertainty remains about Medicare billing. On that date, the state converted every existing advanced practice nurse prescriber credential to an APRN license, creating a path for qualifying nurses to practice without physician collaboration for the first time.

A new era for APRNs in Wisconsin

The act covers four roles: nurse practitioners, certified nurse-midwives, clinical nurse specialists, and certified registered nurse anesthetists. However, independence isn’t automatic. APRNs must meet strict requirements, including 3,840 hours of clinical practice as a registered nurse and an additional 3,840 hours in an APRN role with a physician or dentist available for consultation. At least 24 months must pass for each stage, ensuring a minimum of four years of supervised experience before independent practice is allowed.

Applicants must document these hours on a board-approved form, maintain malpractice coverage, contribute to the state’s Injured Patients and Families Compensation Fund, and pay a fee. The Wisconsin Department of Safety and Professional Services opened the independent practice application in early August, with only approved nurses eligible to drop their collaborative agreements, as noted on their licenses.

Medicare billing uncertainty

While state law permits APRNs to practice independently, federal rules for Medicare Part B only cover nurse practitioner services when performed in collaboration with a physician. It remains unclear if CMS will consider Wisconsin’s new law as meeting this requirement. CMS has not yet provided guidance on this matter, leaving practices uncertain about reimbursement for APRN services.

Certified nurse-midwives are an exception, as Medicare does not require them to have a collaborating agreement if they meet Wisconsin’s requirements. However, for other APRNs, independent state licensure does not ensure independent reimbursement, and commercial payers may impose similar restrictions.

Next steps for Wisconsin practices

Verify each APRN’s hours and months of practice
Confirm malpractice coverage and compensation fund participation
Update bylaws, privilege forms, job descriptions, and employment contracts

The Wisconsin Board of Nursing has warned that APRNs practicing independently without authorization may face disciplinary action. The board is currently operating under emergency rules, with permanent rules forthcoming. APRN licenses will next renew in February 2028, providing a timeline for further regulatory developments.

After facing opposition from physician groups, the bill gained momentum when Gov. Tony Evers added longer supervision requirements, pain management limits, and title protections. Gov. Evers vetoed earlier versions of the bill in 2022 and 2024, but the 2025 version included these critical changes. The Wisconsin Medical Society shifted to a neutral stance, acknowledging that lawmakers had addressed their concerns, particularly regarding patient safety and role clarity.