Can a Nurse Practitioner Own a Weight Loss Clinic? By State
A nurse practitioner who wants to open a weight loss, GLP-1, or longevity clinic is really asking two legal questions, and most guides answer only one. The first is scope of practice: can the NP diagnose, treat, and prescribe without a physician agreement? On the American Association of Nurse Practitioners’ May 2026 state practice map, 27 states plus DC grant full practice, 12 states are reduced practice, and 11 states are restricted practice.
The second question is ownership: can the NP own the entity that bills for the care? That is a separate analysis, governed by professional-entity statutes and the corporate practice of medicine doctrine, and the AANP category says nothing about it. A full-practice state can still block an NP from owning a medical corporation, and a restricted-practice state can let an NP own a practice outright.
This guide separates the two, gives a 50-state table (plus DC) with primary-source citations for each row, explains what a management services organization may and may not control, and lists what a collaborative agreement has to contain in the states that require one. Where a state’s ownership rule could not be confirmed from a primary source, the table says “verify with board” rather than guess. Current as of October 2026.
Two questions, not one: scope of practice vs. who owns the clinic
The AANP defines the three practice categories this way (as of May 2026):
- Full practice: “State practice and licensure laws permit all NPs to evaluate patients; diagnose, order and interpret diagnostic tests; and initiate and manage treatments, including prescribing medications and controlled substances, under the exclusive licensure authority of the state board of nursing.”
- Reduced practice: “State law requires a career-long regulated collaborative agreement with another health provider in order for the NP to provide patient care, or it limits the setting of one or more elements of NP practice.”
- Restricted practice: “State law requires career-long supervision, delegation or team management by another health provider in order for the NP to provide patient care.”
Those definitions describe who may treat patients and under whose authority. Ownership turns on different law: each state’s professional corporation or professional service statute lists which licensees may hold shares, and states with a corporate practice of medicine (CPOM) doctrine add a rule that a business entity other than a licensed physician should not control medical decisions. In California, for example, the statute says “Corporations and other artificial legal entities shall have no professional rights, privileges, or powers” (Bus. & Prof. Code 2400).
Much medical spa and weight loss content blurs the two. “Full practice” gets read as “can own anything,” or “needs a collaborating physician” gets read as “must be owned by a physician.” Neither follows. The practical sequence is to check scope of practice first, then the entity statute, then the corporate practice rules, then the prescribing rules for the drugs the clinic will actually use.
Which states let a nurse practitioner practice without a physician agreement?
Twenty-seven states plus DC are full practice on the AANP map, but nine of them still require a transition period before an NP is independent, and two have a narrower condition tied to prescribing. The rest have no agreement requirement at all. All figures below are as of the statutes and rules cited in the 50-state table.
| Group | States and the condition |
|---|---|
| Full practice with a transition period | Connecticut (3 years and 2,000 hours in collaboration, then written notice to the Department of Public Health), Maine (24 months under a physician or supervising NP, or employment by a clinic with a physician medical director), Maryland (18-month mentor for first-time certificants, no agreement), Massachusetts (2 years of supervised practice after certification), Minnesota (2,080 hours under a collaborative agreement in a hospital or integrated setting), Nebraska (2,000-hour transition-to-practice agreement), New York (3,600 hours), South Dakota (1,040 practice hours), Vermont (24 months and 2,400 hours) |
| Full practice with a prescribing condition | Colorado (3 years of combined RN/APRN experience plus a 750-hour prescribing mentorship), Nevada (Schedule II only after 2 years or 2,000 hours, or under a protocol approved by a collaborating physician) |
| Full practice, no agreement | Alaska, Arizona, Delaware, DC, Hawaii, Idaho, Iowa, Kansas, Montana, New Hampshire, New Mexico, North Dakota, Oregon, Rhode Island, Utah, Washington, Wyoming |
Several reduced and restricted states also have graduation paths: Arkansas (certificate of full independent practice after 6,240 hours), Illinois (4,000 clinical hours plus 250 hours of continuing education), West Virginia (3 years of prescriptive practice), Oklahoma (independent prescribing after 6,240 supervised hours), Virginia (3 years, cut from 5 in 2024), California (103 NP and 104 NP pathways), Florida (autonomous practice limited to primary care), and Kentucky (exemption after 4 years). The table lists each. For a weight loss clinic, note that Florida’s autonomous practice is limited to primary care, so a weight management business there should not assume the pathway covers it without checking with the board.
Can a nurse practitioner own a medical practice? The 50-state table
The table below covers all 50 states and DC. “Practice authority” is the AANP category from the May 2026 map. “Can the NP own the entity?” reads “Yes, cited” only where a statute or board document names nurses as eligible owners of a professional entity or says NPs may own a practice. “Nursing entity only” means the NP may form a nursing professional entity but not own a medical corporation. “CPOM, see below” means the corporate practice rules shape the answer and the next section explains them. “Verify with board” means no primary source settled the question. All sources were fetched October 1, 2026, and state legislatures change these rules every year.
| State | Practice authority (AANP, May 2026) | Physician agreement | Key terms | Can the NP own the entity? |
|---|---|---|---|---|
| Alabama | Reduced | Yes, written protocol signed by a collaborating physician (Ala. Code 34-21-85) | Physician present 10% of CRNP hours until 2 years/4,000 hours; quarterly QA; remote sites visited twice a year (540-X-8-.08); cap of 360 hours a week (9 FTE) (540-X-8-.12); Schedule III-V requires a QACSC | Yes, cited: the ABN FAQ says the rules “do not prohibit a CRNP or CNM from owning a practice” |
| Alaska | Full | No (AS 08.68.410) | None | verify with board |
| Arizona | Full | No (A.R.S. 32-1601) | None | Yes, cited: A.R.S. 10-2220 (licensed persons hold PC shares; other persons capped at 49%) |
| Arkansas | Reduced | Yes until 6,240 hours, then a certificate of full independent practice (17-87-314) | Agreement covers availability, protocols, emergency coverage, QA (statute PDF); Schedule II opioids 5-day limit | verify with board |
| California | Restricted | Yes, standardized procedures with a supervising physician (BPC 2836.1), unless a 103 NP or 104 NP | 1 physician to 4 NPs; 103 NP after 3 years/4,600 hours in a group setting with a physician (2837.103); 104 NP after 3 more years, may practice outside a group (2837.104); Schedule II/III need a patient-specific protocol | CPOM, see below: BPC 2400; Corp. Code 13401.5 lets RNs hold up to 49% of a medical corporation; a nursing corporation (BPC 2775) is the NP-owned vehicle |
| Colorado | Full | No, but a “safe mechanism for consultation or collaboration” with a physician (12-255-111(5)) | Prescriptive authority: 3 years combined RN/APRN experience plus a 750-hour prescribing mentorship; $500,000 per claim liability coverage for independent practice | verify with board (12-240-138 limits medical PCs to physicians and PAs; the nursing entity form was not located) |
| Connecticut | Full | Yes until 3 years AND 2,000 hours in collaboration, then written notice to DPH (DPH) | Written collaboration sets the Schedule II/III level and an outcome review method | verify with board |
| Delaware | Full | No; collaborative agreements repealed effective Aug. 4, 2021 (24 Del. C. ch. 19) | None | Yes, cited: 8 Del. C. 605 (persons licensed to render “the same professional service” may form a professional service corporation) |
| District of Columbia | Full | No, “independent performance” (3-1201.02) | None | verify with board |
| Florida | Restricted | Yes, protocol maintained on site with a supervising physician (464.012), unless registered for autonomous practice (464.0123) | Autonomous: 3,000 hours in 5 years, graduate differential diagnosis and pharmacology, primary care only; Schedule II limited to 7-day supply | Yes, cited: 400.9905(4)(g) exempts clinics “wholly owned by one or more licensed health care practitioners” including 464.012 APRNs from Health Care Clinic Act licensure; chapter 621 covers PSC/PLLC |
| Georgia | Restricted | Yes, nurse protocol agreement with a delegating physician (O.C.G.A. 43-34-25; Rule 360-32) | 100% of controlled-substance charts reviewed quarterly; 10% of other charts annually (360-32-.02); cap of 8 APRNs/PAs per physician (effective May 25, 2026); out-of-state physician within 50 miles; no Schedule II except emergency hydrocodone/oxycodone | CPOM, see below: Rule 360-32-.04(5) bars the delegating physician from being the APRN’s employee |
| Hawaii | Full | No (HRS 457) | None | verify with board |
| Idaho | Full | No, “licensed independent practitioner” (IDAPA 24.34.01.200) | None | verify with board |
| Illinois | Reduced | Yes until full practice authority: 4,000 clinical hours plus 250 CE hours (68 Ill. Adm. Code 1300.465) | Under an agreement, Schedule II limited to a 30-day supply with monthly discussion; FPA-APRNs prescribe Schedule II opioids only through a consultation relationship | Nursing entity only: the Medical Corporation Act (805 ILCS 15/13) limits medical corporation ownership to Medical Practice Act licensees; an NP may form a nursing professional corporation; verify with board |
| Indiana | Reduced | Yes, practice agreement with a licensed practitioner (IC 25-23-1-19.4) | At least 5% random chart sample; prescribing documentation to the physician within 7 days (848 IAC 5-1-1); “geographic proximity,” no mileage | Yes, cited: IC 23-1.5-2-3 (any “health care professional” may form a PC) |
| Iowa | Full | No (481 IAC 621.4; Iowa Code 147.107) | None | Yes, cited: Iowa Code 496C.2(4)(x) lists “the practice of nursing” |
| Kansas | Full | No (K.S.A. 65-1130) | Malpractice insurance required | Yes, cited: K.S.A. 17-2707(b)(18) “a registered professional nurse” |
| Kentucky | Reduced | Yes: CAPA-NS for legend drugs (exempt after 4 years); CAPA-CS for controlled substances (exempt after 4 years) (KRS 314.042) | CAPA-CS meetings quarterly in year 1, twice a year in years 2-4; Schedule II 72-hour supply (hydrocodone combination products 30 days), Schedule III 30 days (KRS 314.011); first-year APRN must be employed by a health care entity | verify with board (KRS 274.015 allows same-profession PSCs) |
| Louisiana | Reduced | Yes, collaborative practice agreement (La. R.S. 37:913) | 500 clinical hours within 2 years before prescriptive authority; no more than two collaborating physicians per site; guidelines reviewed annually; APRN may not use controlled substances to treat obesity (LAC 46:XLVII.4513) | Yes, cited: La. R.S. 12:1075 professional nursing corporations (only licensed nurses vote) |
| Maine | Full | 24 months under a physician or supervising NP (or clinic employment with a physician medical director), then no (32 M.R.S. 2102) | None after transition | Yes, cited: 13 M.R.S. 723(7)(A) lists advanced practice registered nurses |
| Maryland | Full | No agreement; 18-month mentor (NP or physician with 3+ years) for first-time certificants (COMAR 10.27.07.02) | None | verify with board (the PSC statute does not list nursing) |
| Massachusetts | Full | 2 years of supervised practice after certification, then independent prescriptive authority (c.112 80E) | Until then, prescribe under guidelines with a supervising physician or independent NP | Yes, cited: M.G.L. c.156A 2(b) lists registered nurses |
| Michigan | Restricted | Controlled substances only as a delegated act of a physician (MCL 333.17211a) | Both DEA numbers on controlled-substance prescriptions | Nursing entity only: MCL 450.1284 requires all shareholders to hold the same profession; an NP cannot co-own a physician PC |
| Minnesota | Full | 2,080 hours under a collaborative agreement in a hospital or integrated setting, then no (148.211) | None after transition | Yes, cited: Minn. Stat. 319B.02 subd. 19 lists registered nursing |
| Mississippi | Reduced | Yes, collaborative relationship with a physician under a protocol (Miss. Code 73-15-20; MSBN Part 2840) | Physician reviews 10% or 20 charts (whichever is less) monthly; quarterly face-to-face or video meeting; physician practices in Mississippi 20 hours a week; more than 75 miles is “extended mileage” needing board approval (MSBML rules); no Schedule II for weight loss | verify with board |
| Missouri | Restricted | Yes, collaborative practice arrangement (RSMo 334.104) | 10% of charts every 14 days; 20% of controlled-substance charts; physician on site at least every 2 weeks; 6 FTE cap; “geographic proximity” (the 75-mile figure was removed in 2024) (20 CSR 2200-4) | Yes, cited: RSMo 356.021 lists “a registered nurse”; whether the NP entity may employ its collaborating physician: verify with board |
| Montana | Full | No, “independent and/or collaborative practice” (ARM 24.159.1406; MCA 37-8-409) | None | Yes, cited: MCA 35-4-205 (single-profession PC) |
| Nebraska | Full | 2,000-hour transition-to-practice agreement (supervisor may be a physician or an NP with 10,000 hours), then no (38-2322) | None after transition | Yes, cited: Neb. Rev. Stat. 21-2204 (same professional service) |
| Nevada | Full | No (NRS 632.237) | Schedule II only after 2 years or 2,000 hours, or under a protocol approved by a collaborating physician | verify with board (NRS 89.050 allows a professional entity for “one specific type of professional service” and does not name nursing) |
| New Hampshire | Full | No, “plenary authority” (RSA 326-B:11) | None | Yes, cited: RSA 294-A:8 |
| New Jersey | Reduced | Yes, joint protocol with a collaborating physician, unless exempt under P.L.2026, c.6 (approved March 30, 2026) | Protocol reviewed, updated, and signed at least annually; charts “periodically reviewed”; physician present or readily available electronically; exemption needs 5,000+ hours, primary care or behavioral health, no elective aesthetic or cosmetic services | CPOM, see below: N.J.A.C. 13:35-6.16(f) allows entities of “closely allied” health professions including nursing |
| New Mexico | Full | No, “practice independently” (NMSA 61-3-23.2) | None | verify with board |
| New York | Full | Yes until 3,600 hours (written practice agreement and protocols; physician record review at least every 3 months), then no (Education Law 6902) | Collaboration is not supervision (NYSED); the current text of 6902(3)(b) is marked effective until July 1, 2030, when a revised version takes its place | CPOM, see below: BCL 1503 and 1507; an NP-owned PC/PLLC for NP services; physician-NP co-ownership: verify with board |
| North Carolina | Restricted | Yes, collaborative practice agreement with a supervising physician (G.S. 90-18.2; 21 NCAC 32M .0110) | Monthly meetings for the first 6 months, then at least every 6 months; agreement reviewed yearly; continuous availability | Yes, cited for joint ownership: G.S. 55B-14(c)(5) (a physician and any combination of nurse practitioners may form one PC); NP-only PC: verify with board |
| North Dakota | Full | No (NDAC 54-05-03.1) | None | Yes, cited: NDCC 10-31-07 (same specific professional services) |
| Ohio | Reduced | Yes, standard care arrangement with each collaborating physician (ORC 4723.431) | A physician may collaborate with no more than 5 nurses in the prescribing component; random chart review at least annually (OAC 4723-8-05); Schedule II outside listed settings only for terminal patients, physician-initiated, 72-hour supply | Yes, cited: ORC 1785.02 lists nurses and physicians in the professional-association group; confirm the multi-profession reading with the board |
| Oklahoma | Restricted | Yes, supervising physician and written supervision agreement for prescribing; HB 2298 (effective Nov. 1, 2025) lets a CNP apply for independent prescribing after 6,240 supervised hours (HB 2298) | Schedules III-V only; 30-day supply (OAC 485:10-16-5); $1M/$3M malpractice; supervision fees at a fair market value hourly rate; any cap on supervisees is left to board rule | Nursing entity only: 18 O.S. 803 lists registered nurses as a professional service, but its physician combination list does not include nurses; verify with board |
| Oregon | Full | No (OAR 851-055-0010) | None | Yes, cited: ORS 58.503 (physicians, physician associates, and NPs may jointly form a PC); SB 951 (2025) bars MSO owners and officers from controlling the entity they manage |
| Pennsylvania | Reduced | Yes, collaborative agreement and prescriptive authority collaborative agreement (49 Pa. Code 21.251, 21.283) | Agreement names at least one substitute physician, says how often the physician personally sees patients, reviewed at least every 2 years (21.285); Schedule II 30-day supply, Schedule III/IV 90-day supply (21.284); no ratio in the current rules; SB 25 and HB 739 (full practice) were still in committee as of October 2026 | Yes, cited: 15 Pa.C.S. 2923(a) (all beneficial owners must be licensed persons); physician-CRNP co-ownership: verify with board |
| Rhode Island | Full | No, “licensed, independent practitioners” (5-34-44) | None | Yes, cited: R.I. Gen. Laws 7-5.1-2 lists registered nurses |
| South Carolina | Restricted | Yes, practice agreement with a physician readily available for consultation (40-33-34) | Physician cap of 6 FTE APRNs/PAs (40-47-195); agreement reviewed annually; Schedule II narcotic 5-day supply, nonnarcotic 30-day; the 45-mile rule was repealed in 2018; H.3580 (full practice after 2,000 hours) was still in the House as of October 2026 | Yes, cited: 33-19-200 (shares to licensed individuals) and a 2023 joint board opinion (“100% practitioner owned (MD, DO, APRN, PA)”) |
| South Dakota | Full | 1,040 practice hours under a collaborative agreement (physician or experienced CNP), then no (36-9A-4) | None after transition | Yes, cited: SDCL 47-11E-1 nursing corporations |
| Tennessee | Restricted | Yes, collaborating physician with “control and responsibility” for prescriptive services (Rule 1000-04-.04; T.C.A. 63-7-123) | Physician personally reviews 20% of charts every 30 days and visits remote sites every 30 days (Rule 0880-06-.02); no numeric supervisee cap (BME FAQ) | CPOM, see below: AG Op. 07-116 says an NP may not own a PC or PLLC for medical services but may own a practice where services are under physician control |
| Texas | Restricted | Yes, prescriptive authority agreement with a delegating physician (Occ. Code 157.0512; 22 TAC 222) | Meetings at least monthly in any format; chart review count set by the parties; 7 FTE cap per physician (TMB); agreement reviewed annually; Schedule II only in hospital or hospice practice; Schedule III-V up to 90 days | CPOM, see below: Occ. Code 164.052(a)(17); Bus. Orgs. Code 301.012 does not list APRNs as eligible joint owners of a medical professional entity; NP-owned structure: verify with the Texas Medical Board |
| Utah | Full | No (Nurse Practice Act re-enacted effective May 6, 2026) (58-31b-302) | None | Yes, cited: Utah Code 16-11-2(3) |
| Vermont | Full | Collaborative provider agreement for the first 24 months AND 2,400 hours; no solo practice until met (26 V.S.A. 1613) | None in statute | verify with board |
| Virginia | Restricted | Yes, practice agreement with a patient care team physician until 3 years of full-time experience and an attestation (54.1-2957(I)); full time is 1,800 hours a year (18VAC90-30-86), cut from 5 years in 2024 (Virginia Register) | Physician cap of 6 APRNs (10 in listed settings) (54.1-2957.01); chart review at a frequency the parties set | Yes, cited: Va. Code 13.1-543 deems APRNs and healing arts practitioners the same professional service, so NPs may own a PC alone or with physicians |
| Washington | Full | No, “licensed independent practitioner” (WAC 246-840-300) | None | Yes, cited: RCW 18.100.050(5)(a); case-law CPOM for NP entities employing physicians: verify with board |
| West Virginia | Reduced | Collaborative agreement for at least 3 years of prescriptive practice, then none (30-7-15b(e)) | Schedule II narcotic 3-day supply (30-7-15a) | verify with board (the PLLC statute lists physicians, not nurses) |
| Wisconsin | Reduced | Yes, collaboration with a physician or dentist until 3,840 RN hours (24 months) plus 3,840 APRN hours (24 months), under 2025 Wis. Act 17 effective Sept. 1, 2026 (441.09) | None in statute | Yes, cited: Wis. Stat. 180.1901 and 180.1903 (health care professionals, including nurses, may own a service corporation) |
| Wyoming | Full | No (33-21-120) | None | Yes, cited: Wyo. Stat. 17-3-101 (corporation owned exclusively by licensed persons) |
Two reading cautions. First, a “Yes, cited” in the ownership column means a professional-entity statute or board document supports NP ownership of an entity, not that the entity can be run without a physician where a collaborating physician is required. Second, a statute that lets an NP and a physician co-own one corporation (North Carolina, Oregon, Virginia) is a different thing from a statute that lets an NP own a corporation alone.
What the corporate practice of medicine doctrine does to ownership
The doctrine is state-specific and often lives in case law and board opinions rather than a single statute. These are the states where the sources reviewed show it shaping an NP-owned clinic.
California. The Medical Board of California’s CPOM guidance lists “Non-physicians owning or operating a business that offers patient evaluation, diagnosis, care and/or treatment” as a prohibited structure. Corporations Code 13401.5 lets registered nurses hold up to 49 percent of a medical corporation, and a nursing corporation under BPC 2775 is the NP-owned vehicle. Under BPC 2837.103 and 2837.104, a 103 NP works in a group setting with at least one physician, and a 104 NP can practice outside a group setting after three more years.
Texas. Occupations Code 164.052(a)(17) makes it a prohibited practice when a physician “directly or indirectly aids or abets the practice of medicine by a person, partnership, association, or corporation that is not licensed to practice medicine by the board.” Business Organizations Code 301.012 lists physicians, podiatrists, and chiropractors as joint owners, and physicians with physician assistants, but does not list APRNs. Whether and how an NP can own a Texas entity that employs a delegating physician is a question to put to the Texas Medical Board.
New York. Business Corporation Law 1503 and 1507 limit professional corporation shares to individuals authorized to practice the profession the corporation practices. Education Law 6530(19) makes it misconduct for a physician to permit “any person to share in the fees for professional services, other than: a partner, employee, associate in a professional firm or corporation, professional subcontractor or consultant authorized to practice medicine” (6530). An NP-owned PC or PLLC fits NP services; whether a physician and NP may co-own should be confirmed with the board.
New Jersey. The Board’s rule at N.J.A.C. 13:35-6.16(f) allows entities composed solely of health care professionals in “closely allied” fields, and names nursing among them. Separately, P.L.2026, c.6, approved March 30, 2026, exempts some APNs from the joint protocol requirement, but only for an APN with more than 5,000 hours of advanced practice, providing primary health care or behavioral health care, outside general obstetrics, and “not providing elective aesthetic or cosmetic services.” An NP with fewer than 5,000 hours still needs a joint protocol, and so does any APN whose services fall on the aesthetic side of that line. The statute does not say where a weight loss program sits, so confirm with the board before relying on the exemption.
Tennessee. Attorney General Opinion 07-116 (Aug. 8, 2007) says “It is not lawful for a certified nurse practitioner … to own and operate a professional corporation or professional limited liability company (‘PLLC’) for the provision of medical services.” The same opinion says an NP may own a practice where medical services are provided “under the ‘supervision, control and responsibility’ of a licensed physician,” and that a physician may serve as an independent contractor but not as the NP’s employee solely to provide supervision. The opinion predates the 2024 rule change to “collaborating physician” wording.
Georgia. Rule 360-32-.04(5) says “a physician shall not be an employee of an APRN, alone or in combination with others, if the physician delegates to and/or is required to supervise the employing APRN,” with an exception for practice settings listed in O.C.G.A. 43-34-25(g)(7). Outside those settings, an NP-owned Georgia clinic cannot put its own delegating physician on payroll.
Illinois and Michigan. Both draw the line at the entity type. Illinois’s Medical Corporation Act (805 ILCS 15/13) requires officers, directors, and shareholders of a medical corporation to be licensed under the Medical Practice Act, so an NP may form a nursing professional corporation but not own a medical corporation. Michigan’s MCL 450.1284 requires every shareholder of a professional corporation to be licensed in the same profession, so an NP cannot co-own a physician PC.
Oregon. SB 951 (2025) bars an MSO, and any shareholder, director, officer, or employee of an MSO, from owning or controlling, serving as a director or officer of, or managing a professional medical entity with which the MSO has a management contract. It was effective on passage. Oregon also lets physicians, physician associates, and NPs jointly form a PC under ORS 58.503.
The friendly PC plus MSO structure: what the MSO may and may not control
In states that restrict ownership, the common workaround is a “friendly PC” owned by a licensed physician, paired with a management services organization (MSO) owned by the NP or investors. The MSO leases space, supplies staff, and handles marketing and billing; the PC employs or contracts the clinicians. The structure is lawful only as long as the MSO stays on the administrative side of a line that regulators draw clearly.
The Medical Board of California’s guidance (the clearest published list, though it applies only in California) says decisions that must be made by a physician include “Determining what diagnostic tests are appropriate for a particular condition,” determining referrals and consultations, “Responsibility for the ultimate overall care of the patient, including treatment options available to the patient,” and how many patients a physician must see or how many hours a physician must work. Business decisions that must stay with the licensed physician include ownership of medical records, “Selection, hiring/firing (as it relates to clinical competency or proficiency) of physicians, allied health staff and medical assistants,” payer contracting parameters, “Decisions regarding coding and billing procedures for patient care services,” and approval of medical equipment and supplies.
The Board then states: “The types of decisions and activities described above cannot be delegated to an unlicensed person, including (for example) management service organizations.” A physician may consult with unlicensed persons on business decisions but “must retain the ultimate responsibility for, or approval of, those decisions.” Prohibited structures on the Board’s list include non-physicians owning a business that offers evaluation and treatment, and MSOs “arranging for, advertising, or providing medical services rather than only providing administrative staff and services.”
The “medical director” trap is on that list too: “A physician acting as ‘medical director’ when the physician does not own the practice,” for example a spa that offers Botox and contracts with a physician as its medical director. For cosmetic and aesthetic services, BPC 2417.5 treats a business offering outpatient elective cosmetic medical procedures that does not comply with the CPOM ban as making a false claim under Penal Code 550(a)(6).
Oregon’s SB 951, covered above, goes further by barring MSO owners and officers from controlling the medical entity they manage. Florida shows the opposite end of the spectrum: Fla. Stat. 400.9905(4)(g) exempts a clinic “wholly owned by one or more licensed health care practitioners,” including 464.012 APRNs, from Health Care Clinic Act licensure. In Florida the question is less “can an NP own it” than “what does the supervising physician protocol require.”
What a collaborative practice agreement must contain
In reduced and restricted states, the agreement is the document regulators actually audit. The table covers 17 states as of October 1, 2026 and shows how widely the terms differ. “Not set” means the sources reviewed found no fixed number in the statute or rule; the parties often set it in the agreement.
| State | Chart review | Meetings | Prescriptive limits | Ratio or distance |
|---|---|---|---|---|
| Texas | Count set by the parties | At least monthly, any format; agreement reviewed annually | Schedule II only in hospital or hospice practice; Schedule III-V up to 90 days | 7 FTE cap; the former face-to-face and 3-year language was repealed in 2019 |
| Florida | Not set in statute | Not set | Schedule II limited to 7-day supply | Protocol kept on site; no ratio or distance in statute |
| Pennsylvania | Not set; agreement says how often the physician sees patients | Agreement reviewed at least every 2 years | Schedule II 30-day; Schedule III/IV 90-day | No ratio, chart percentage, or distance in current rules; at least one substitute physician named |
| Georgia | 100% of controlled-substance charts quarterly; 100% of adverse outcomes within 30 days; 10% of others annually (360-32-.02) | Quarterly collaboration meetings; annual onsite observation (360-32-.05) | Schedule I and II excluded except emergency hydrocodone/oxycodone | 8 APRNs/PAs per physician from May 25, 2026; out-of-state physician within 50 miles |
| Missouri | 10% every 14 days; 20% of controlled-substance charts | Physician on site at least once every 2 weeks | Schedule III narcotic and Schedule II hydrocodone: 120-hour supply | 6 FTE; “geographic proximity” (75 miles removed in 2024); 1 month of continuous presence before off-site practice |
| Tennessee | 20% every 30 days | Remote site visited every 30 days | Not covered in the sources reviewed | No numeric supervisee cap |
| Mississippi | 10% or 20 charts, whichever is less, monthly | Face-to-face or video quarterly | No Schedule II for weight loss; stimulants 30-day supply | More than 75 miles needs board approval; physician in state 20 hours a week |
| Alabama | 100% during provisional period; quality assurance quarterly | Physician present 10% of hours until 2 years/4,000 hours; remote sites twice a year | Schedule III-V requires QACSC | 360 hours a week (9 FTE) per physician |
| Ohio | Random review at least annually | Not set | Schedule II only for terminal patients outside listed settings, 72-hour supply | No more than 5 nurses in the prescribing component |
| Kentucky | Not set | CAPA-CS quarterly in year 1, twice a year in years 2-4 | Schedule II 72 hours (hydrocodone combinations 30 days); Schedule III 30 days; IV-V up to 6 months | Not set |
| North Carolina | Not set | Monthly for 6 months, then at least every 6 months; agreement reviewed yearly | Not covered in the sources reviewed | Not set |
| South Carolina | Not set | Agreement reviewed annually | Schedule II narcotic 5 days, nonnarcotic 30 days | 6 FTE; the 45-mile rule was repealed in 2018 |
| Virginia | At a frequency the parties set | Not set | Not covered in the sources reviewed | 6 APRNs (10 in listed settings) |
| Indiana | At least a 5% random sample | Prescribing documentation to the physician within 7 days | Not covered in the sources reviewed | “Geographic proximity,” no mileage |
| Louisiana | Guidelines reviewed and signed annually | Not set | No controlled substances to treat obesity | No more than two collaborating physicians per site |
| New Jersey | “Periodically reviewed,” no percentage | Joint protocol reviewed, updated, and signed annually | Protocol addresses prior consultation for controlled substances | Physician present or readily available electronically |
| Oklahoma | Not set in statute | Written supervision agreement | Schedules III-V only, 30-day supply | Ratio left to Medical Board rule |
Sources are in the 50-state table above. Two corrections of widely repeated numbers: Missouri’s 75-mile limit is no longer in the rule text (the statute now says “geographic proximity”), and South Carolina’s 45-mile rule was repealed in 2018. Texas’s older face-to-face and three-year language was repealed in 2019 by HB 278. Pennsylvania’s current rules contain no physician-to-CRNP ratio. Secondary summaries still circulate the old figures, so check the rule text, not a summary.
Weight-loss-specific prescribing rules to check
Scope-of-practice rules decide who may prescribe. A smaller set of rules decides what may be prescribed for weight loss.
GLP-1 drugs are not controlled substances. Semaglutide, tirzepatide, and liraglutide do not appear in the federal schedules (21 CFR Part 1308), while phentermine is listed in Schedule IV (21 CFR 1308.14). Because most state limits bite on Schedule II, the general prescriptive limits above matter less for a weight clinic than the diet-drug rules below. The DEA telemedicine rule discussed later applies to the controlled drugs only.
Mississippi. The state’s “obesity-specific rules” are controlled-substance rules, and nothing GLP-1-specific was found. Under MSBN Part 2840, Rule 1.5(E), “The APRN shall not prescribe any Schedule II controlled substance for the exclusive treatment of obesity, weight control, or weight loss.” The same rule prohibits using controlled substances or legend drugs for weight loss unless the drug has an FDA-approved indication for that purpose, and sets conditions: documented prior good-faith non-drug attempts, a history and physical, weigh-ins at least every 30th day, stimulant prescriptions of no more than a 30-day supply, and no more than a 3-month supply (including refills) of non-stimulant FDA-approved long-term agents, with reevaluation before renewal. The Mississippi physician board has a parallel rule (Part 2640, Rule 1.5, last amended October 1, 2023) that also bars Schedule II for exclusive treatment of obesity and requires the licensee providing comprehensive obesity treatment to be present at the facility when prescribing or dispensing controlled substances for weight reduction (MSBML rules).
Louisiana. An APRN with controlled-substance authority “shall not utilize such substances in connection with the treatment of” obesity, as defined in the board’s rules (LAC 46:XLVII.4513). That language is in the APRN rule; it is not a statement about GLP-1 drugs.
Ohio. The Schedule II prescribing limit has a site exemption for “A site where a medical practice is operated, but only if the practice is comprised of one or more physicians who also are owners of the practice” (ORC 4723.481). An NP-owned clinic with no physician owner does not fit it.
Georgia and Florida. Georgia excludes Schedule II from the nurse protocol agreement except emergency hydrocodone and oxycodone, and Florida limits Schedule II to a 7-day supply (see the tables above).
What a collaborating physician costs
Published data is thin. The one public data point is a report from a marketplace that matches NPs with collaborating physicians. NP Collaborator’s “Fair Price for Collaboration Report, Edition 1” (August 18, 2026) says it covers “2,000+ real signed contracts across 20 states.” It reports a national median of $549 a month, a medical weight loss median of $499, and an aesthetics or med spa median of $599, with state medians of $649 in Georgia, Alabama, and California and $499 in Texas, Florida, and Pennsylvania. The figures are “total monthly fees including physician fees, platform fees, and physician malpractice insurance.” This is a marketplace’s own report on contracts it analyzed (it says the set includes arrangements made off its platform), not an independent survey, and a direct arrangement may price differently.
Three state rules limit what a physician may charge or require. Oklahoma’s HB 2298 requires supervision fees at “a fair market value hourly rate.” Mississippi’s physician board rule 1.7 says physicians who bill APRNs for collaboration “should negotiate at rates considering fair market value.” Colorado says a prescribing mentor “shall not require payment or employment as a condition of entering into the mentorship” (C.R.S. 12-255-112).
What changes when you add a second state by telehealth
Adding a patient in another state adds a licensing question, a collaboration question, and a corporate practice question, and each one repeats state by state.
Licensure. The Nurse Licensure Compact FAQ says: “The NLC pertains to RN and LPN/VN licenses only. An APRN must hold an individual APRN license in each state of APRN practice” (nursecompact.com). The APRN Compact would change that, but it is not operational. NCSBN reported on February 9, 2024 that “South Dakota is the fourth jurisdiction to enact the APRN Compact, joining Delaware, North Dakota and Utah,” and “The APRN Compact will be implemented when seven states have enacted the legislation” (NCSBN). Four states have enacted it and seven are needed, and the Texas Board of Nursing’s July 2026 update memo reports the same four. Wyoming’s 2016 enactment was of the earlier version of the compact and is not counted.
Florida registration. Fla. Stat. 456.47 lets a health care professional licensed elsewhere register to provide telehealth to Florida patients, but “may not open an office in this state and may not provide in-person health care services to patients located in this state.” Schedule II controlled substances by telehealth are limited to psychiatric disorders and a few institutional settings.
Collaborating physician location. The physician usually has to be licensed in the patient’s state. Pennsylvania: “A CRNP may collaborate only with physicians who hold a current license to practice in this Commonwealth” (21.282a). Alabama’s board FAQ says a CRNP must enter a collaborative agreement with “a physician licensed in the state of Alabama” (ABN FAQ). Georgia’s physician must have an active state license and practice within the state or within 50 miles of the patient, which “applies to both in-person and telehealth services provided by an APRN and is independent of the business model” (GCMB). Mississippi requires the collaborating physician to practice in the state at least 20 hours a week (MSBML rules).
Controlled substances. The DEA’s fourth temporary extension of telemedicine flexibilities runs through December 31, 2026 and allows DEA-registered practitioners to prescribe Schedule II-V controlled substances via telemedicine without a prior in-person evaluation (90 FR 61301). It matters for phentermine (Schedule IV), not for GLP-1s. State rules, such as Mississippi’s diet-drug conditions, still apply on top of it.
Corporate practice. The ownership analysis does not carry over. A structure that works in Pennsylvania or Oregon may be a problem in Tennessee or Texas, so run the CPOM question again for every state where a patient is located.
Checklist before you sign a lease
- Confirm the AANP category for your state, then read the statute or rule behind it, since categories change yearly.
- Decide whether the NP will own the clinical entity, and check the professional-entity statute for that state (the 50-state table above).
- If the table says “verify with board,” get the answer in writing from the board of nursing and the medical board before forming the entity.
- Check whether the collaborating physician may be your employee. Georgia and Tennessee say no in the sources above.
- If you plan a PC plus MSO structure, list every decision the MSO will make and compare it with the California list above and any state-specific rule, including Oregon SB 951.
- Read the agreement requirements for your state: chart review percentage, meeting cadence, ratio, distance, and renewal interval.
- Check diet-drug and Schedule II rules for any controlled drug you plan to prescribe (Mississippi and Louisiana are the strictest examples above).
- Confirm the collaborating physician’s fee against any state fair-market-value rule (Oklahoma, Mississippi, Colorado).
- For each additional state of telehealth, confirm the individual APRN license, the in-state collaborating physician, and the CPOM analysis.
- Put the December 31, 2026 DEA telemedicine expiration on your calendar if you prescribe controlled drugs remotely.
- If you sell memberships, review auto-renewal rules before the first sign-up.
This is not legal advice
This post summarizes primary sources fetched on October 1, 2026 and is not legal advice. State legislatures and boards change scope-of-practice, entity, and prescribing rules every year, several of the rules above were amended in 2025 or 2026, and the corporate practice doctrine is often unwritten case law. Before forming an entity, signing a collaborative agreement, or prescribing controlled drugs, confirm the current rule with your state board of nursing, your medical board, and a health care attorney licensed in your state.
A nurse practitioner running a weight loss clinic with a collaborating physician needs a record system that handles more than one kind of provider. PrismEHR supports multi-provider roles, documentation templates, eRx with EPCS, a patient portal, built-in messaging, video telehealth for a second-state scenario, labs and orders, and memberships. See how it fits a wellness practice, and read how auto-renewal laws affect clinic memberships.