NJAFP Opposes S-2996: APN Independent Practice
Statement on S-2996: APN Independent Practice
EO 112 Shifted APN Practice Patterns, Did Not Improve Primary Care Access
On behalf of the New Jersey Academy of Family Physicians (NJAFP), we are sharing our opposition to S-2996, concerns of our member Board Certified family medicine physicians, and insight on EO 112.
As you consider this legislation it is important up front to reinforce that primary care, particularly family medicine, is a complex specialty, requiring the ability to diagnose, manage, and treat patients of all ages, multiple chronic conditions, and undifferentiated symptoms across the lifespan. It isn’t easy and requires extensive medical and residency training providing the depth of knowledge necessary to provide comprehensive care to our patients. We understand the fundamental barriers well to primary care - low reimbursement, excessive administrative burden, and rising patient complexity. Independent practice authority does not address these systemic challenges and, as demonstrated both during EO 112 and in other states, does not meaningfully grow the primary care workforce or improve quality, outcomes, or costs.
Sponsors of this bill often say granting independent practice authority to Advanced Practice Nurses (APNs) will improve access to primary care. From a practicing family physician’s perspective, the experience following EO 112 demonstrates that practice authority alone does not translate into increased access to primary care. What occurred instead was a redistribution of clinicians away from longitudinal, insured primary care and hospital-based care into cash-based independent practices, including medical spas, dermatology-focused offices, and mobile infusion and “wellness” services. These shifts were not tracked by the State because EO 112 was never intended to facilitate independent practice expansion, but their visibility and growth are undeniable and represent a net loss to essential care delivery.
This pattern is consistent with findings from other states. A 2025 peer-reviewed study examining Florida’s limited autonomous practice model—restricted only to primary care—found that only 328 nurse practitioners pursued autonomous practice statewide, and over 60% were operating outside traditional primary care, largely in medical spas, aesthetic medicine, cosmetic services, IV hydration, and other wellness-based practices (Bernard et al., Family Practice, 2025). Even when autonomy is legally confined to primary care, it does not reliably produce a primary care workforce and may, in practice, accelerate movement away from it.
Concerns regarding quality, utilization, and cost are also supported by national data. An analysis of Veterans Health Administration emergency department encounters from 2017–2020 demonstrated that when nurse practitioners practiced without physician involvement, care was associated with longer emergency department stays, higher diagnostic testing rates, increased overall resource utilization, and higher costs, as well as greater rates of potentially preventable hospital admissions, without improvement in outcomes (Chan & Chen, Stanford/NBER, 2022). These findings underscore that independent practice does not inherently improve efficiency or quality, particularly in higher-acuity or diagnostically complex settings.
Advocates often characterize physician collaboration as nominal or transactional, but this framing is inaccurate. True collaboration means meaningful oversight. It is not a remote or symbolic relationship, nor a “fee for permission.” Collaboration works best for patients when physicians and APNs practice in the same specialty, within the same clinical and insurance networks, and care for patients together as part of an integrated team. Meaningful oversight includes structured communication, shared accountability, and periodic physician chart review and quality assurance, even if the exact frequency is not rigidly defined in statute. These safeguards exist to protect patients and ensure high-quality, coordinated care—precisely what the law originally intended.
It is important to highlight one specific area of the bill are of particular concern - only APNs with under two years of practice must collaborate with either a physician or an APN (new) under a joint protocol. We maintain physician-only collaboration is essential for all, never mind new APNs and patient safety – and any collaboration should require practicing in the same specialty and participating in the same clinical and insurance networks to have true collaboration necessary to support patient care. What does this bill do to protect patients when an APN becomes “new” again after working independently in one specialty for five years and moving into a brand-new specialty without any physician collaboration? APNs often switch specialties over their careers and eliminating physician collaboration during these critical changes in practice is an incredible oversight of this legislation.
As you hear from advocates of S-2996 or calls to extend the EO beyond the February 16th deadline, we encourage you to ask APNs contacting your offices about their current practice, including whether they work independently or collaboratively, and if independently, do they accept insurance and what specialty they actually practice — not just what area they trained. Many “family medicine” trained APNs are often working outside primary care.
For these reasons, NJAFP strongly opposes S-2966 and urges the Legislature to pursue policies that genuinely strengthen primary care access and preserve high-quality, team-based care for New Jersey residents.
Sincerely,
Ken Kronhaus, MD
President, NJ Academy of Family Physicians
*Appendix: Selected Evidence and Workforce Findings
Primary Care Access and Workforce Impact
- Richman et al., Nurse Practitioners’ Workforce Outcomes Under Implementation of Full Practice Authority (Nursing Outlook, 2020).
Independent practice laws did not substantially increase the number of NPs in primary care, showing scope-of-practice reform alone does not grow the primary care workforce. Nurse practitioners’ workforce outcomes under implementation of full practice authority - PMC
- Bernard et al., Autonomous Nurse Practitioners in Florida Frequently Practice Outside Their Legal Scope of Primary Care (Family Practice, 2025).
Despite Florida limiting independent practice to primary care, only 328 APNs pursued autonomous practice, and over 60% practiced in med spas and other non-primary care services, showing independent practice laws do not reliably increase primary care presence. Autonomous nurse practitioners in Florida frequently practice outside their legal scope of primary care: a cross-sectional study - PubMed
Quality, Outcomes, and Costs
- Hattiesburg Clinic Workforce and Outcomes Study (Journal of the Mississippi State Medical Association, 2023).
Expanded APN autonomy did not improve access, did not improve quality outcomes, and was associated with higher costs, while failing to shift clinicians into primary care or underserved roles, indicating independent practice authority alone does not improve access, quality, or affordability. Targeting Value Based Care With Physician Led Care Teams – Access To Care Coalition
- Chan & Chen, Independent NP Resource Utilization and Outcomes (Stanford/NBER, 2022).
Using Veterans Health Administration data (2017–2020), NPs practicing without physician involvement were associated with longer ED stays, higher resource use and costs, and increased preventable hospitalizations, indicating higher costs and lower quality outcomes when NPs practice independently. The Productivity of Professions: Evidence from the Emergency Department | NBER
| Claudine M. Leone
NJ Government Affairs Counsel 224 West State Street |
SPEAK OUT!
Statement on S-2996: APN Independent Practice
EO 112 Shifted APN Practice Patterns, Did Not Improve Primary Care Access
On behalf of the New Jersey Academy of Family Physicians (NJAFP), we are sharing our opposition to S-2996, concerns of our member Board Certified family medicine physicians, and insight on EO 112.
As you consider this legislation it is important up front to reinforce that primary care, particularly family medicine, is a complex specialty, requiring the ability to diagnose, manage, and treat patients of all ages, multiple chronic conditions, and undifferentiated symptoms across the lifespan. It isn’t easy and requires extensive medical and residency training providing the depth of knowledge necessary to provide comprehensive care to our patients. We understand the fundamental barriers well to primary care - low reimbursement, excessive administrative burden, and rising patient complexity. Independent practice authority does not address these systemic challenges and, as demonstrated both during EO 112 and in other states, does not meaningfully grow the primary care workforce or improve quality, outcomes, or costs.
Sponsors of this bill often say granting independent practice authority to Advanced Practice Nurses (APNs) will improve access to primary care. From a practicing family physician’s perspective, the experience following EO 112 demonstrates that practice authority alone does not translate into increased access to primary care. What occurred instead was a redistribution of clinicians away from longitudinal, insured primary care and hospital-based care into cash-based independent practices, including medical spas, dermatology-focused offices, and mobile infusion and “wellness” services. These shifts were not tracked by the State because EO 112 was never intended to facilitate independent practice expansion, but their visibility and growth are undeniable and represent a net loss to essential care delivery.
This pattern is consistent with findings from other states. A 2025 peer-reviewed study examining Florida’s limited autonomous practice model—restricted only to primary care—found that only 328 nurse practitioners pursued autonomous practice statewide, and over 60% were operating outside traditional primary care, largely in medical spas, aesthetic medicine, cosmetic services, IV hydration, and other wellness-based practices (Bernard et al., Family Practice, 2025). Even when autonomy is legally confined to primary care, it does not reliably produce a primary care workforce and may, in practice, accelerate movement away from it.
Concerns regarding quality, utilization, and cost are also supported by national data. An analysis of Veterans Health Administration emergency department encounters from 2017–2020 demonstrated that when nurse practitioners practiced without physician involvement, care was associated with longer emergency department stays, higher diagnostic testing rates, increased overall resource utilization, and higher costs, as well as greater rates of potentially preventable hospital admissions, without improvement in outcomes (Chan & Chen, Stanford/NBER, 2022). These findings underscore that independent practice does not inherently improve efficiency or quality, particularly in higher-acuity or diagnostically complex settings.
Advocates often characterize physician collaboration as nominal or transactional, but this framing is inaccurate. True collaboration means meaningful oversight. It is not a remote or symbolic relationship, nor a “fee for permission.” Collaboration works best for patients when physicians and APNs practice in the same specialty, within the same clinical and insurance networks, and care for patients together as part of an integrated team. Meaningful oversight includes structured communication, shared accountability, and periodic physician chart review and quality assurance, even if the exact frequency is not rigidly defined in statute. These safeguards exist to protect patients and ensure high-quality, coordinated care—precisely what the law originally intended.
It is important to highlight one specific area of the bill are of particular concern - only APNs with under two years of practice must collaborate with either a physician or an APN (new) under a joint protocol. We maintain physician-only collaboration is essential for all, never mind new APNs and patient safety – and any collaboration should require practicing in the same specialty and participating in the same clinical and insurance networks to have true collaboration necessary to support patient care. What does this bill do to protect patients when an APN becomes “new” again after working independently in one specialty for five years and moving into a brand-new specialty without any physician collaboration? APNs often switch specialties over their careers and eliminating physician collaboration during these critical changes in practice is an incredible oversight of this legislation.
As you hear from advocates of S-2996 or calls to extend the EO beyond the February 16th deadline, we encourage you to ask APNs contacting your offices about their current practice, including whether they work independently or collaboratively, and if independently, do they accept insurance and what specialty they actually practice — not just what area they trained. Many “family medicine” trained APNs are often working outside primary care.
For these reasons, NJAFP strongly opposes S-2966 and urges the Legislature to pursue policies that genuinely strengthen primary care access and preserve high-quality, team-based care for New Jersey residents.
Sincerely,
Ken Kronhaus, MD
President, NJ Academy of Family Physicians
*Appendix: Selected Evidence and Workforce Findings
Primary Care Access and Workforce Impact
- Richman et al., Nurse Practitioners’ Workforce Outcomes Under Implementation of Full Practice Authority (Nursing Outlook, 2020).
Independent practice laws did not substantially increase the number of NPs in primary care, showing scope-of-practice reform alone does not grow the primary care workforce. Nurse practitioners’ workforce outcomes under implementation of full practice authority - PMC
- Bernard et al., Autonomous Nurse Practitioners in Florida Frequently Practice Outside Their Legal Scope of Primary Care (Family Practice, 2025).
Despite Florida limiting independent practice to primary care, only 328 APNs pursued autonomous practice, and over 60% practiced in med spas and other non-primary care services, showing independent practice laws do not reliably increase primary care presence. Autonomous nurse practitioners in Florida frequently practice outside their legal scope of primary care: a cross-sectional study - PubMed
Quality, Outcomes, and Costs
- Hattiesburg Clinic Workforce and Outcomes Study (Journal of the Mississippi State Medical Association, 2023).
Expanded APN autonomy did not improve access, did not improve quality outcomes, and was associated with higher costs, while failing to shift clinicians into primary care or underserved roles, indicating independent practice authority alone does not improve access, quality, or affordability. Targeting Value Based Care With Physician Led Care Teams – Access To Care Coalition
- Chan & Chen, Independent NP Resource Utilization and Outcomes (Stanford/NBER, 2022).
Using Veterans Health Administration data (2017–2020), NPs practicing without physician involvement were associated with longer ED stays, higher resource use and costs, and increased preventable hospitalizations, indicating higher costs and lower quality outcomes when NPs practice independently. The Productivity of Professions: Evidence from the Emergency Department | NBER
| Claudine M. Leone
NJ Government Affairs Counsel 224 West State Street |