Yes: a nurse practitioner, physician assistant or physician can open a cash-pay telemedicine hormone practice in Virginia, and the state sits in the workable middle of the map. The gating items are a practice agreement with a patient-care-team physician for NPs (until three years of full-time experience earn autonomous practice) and for PAs, professional-entity laws that decide who may own the clinic, a Virginia licence for anyone treating a patient located in Virginia, and the bona fide practitioner-patient relationship in Va. Code 54.1-3303, which an audio-video visit can establish before a testosterone prescription. This is a 2026 planning summary, not legal advice; confirm every point with the Virginia Board of Nursing, Board of Medicine, Board of Pharmacy and counsel, because rules change.
Virginia practice authority: who can run and own a telemedicine hormone practice
Nurse practitioners in Virginia
Virginia is a reduced practice state. NPs are licensed jointly by the Boards of Medicine and Nursing, and until an NP qualifies for autonomous practice the NP must maintain collaboration and consultation with a patient-care-team physician, documented in a written or electronic practice agreement under Va. Code 54.1-2957. The agreement covers periodic review of health records, input on complex cases, emergencies and referrals, and a periodic joint evaluation of services. A physician may be on a team with no more than six NPs at any one time (ten for psychiatric-mental health NPs), so ask a prospective collaborator how many agreements already carry that signature.
Prescribing runs through the same document. Under Va. Code 54.1-2957.01 an NP prescribes Schedule II through VI drugs (Schedule VI is Virginia’s label for ordinary prescription-only drugs) only as the agreement allows, and the agreement must state which controlled substances the NP is or is not authorized to prescribe. Testosterone, a federal Schedule III drug, must therefore be named; estradiol, progesterone and thyroid medication fall under Schedule VI and should be covered too.
The autonomous-practice pathway is what makes Virginia attractive for an NP-owned clinic. Since July 1, 2024 (2024 Acts, c. 404, implemented in 18VAC90-30-86), an NP with three years of full-time clinical experience under a practice agreement, defined as 1,800 hours per year or 5,400 hours in total, may apply to the Boards to practise without an agreement. The application carries an attestation signed by both the NP and the patient-care-team physician confirming the hours practised together with the same patient population; authorization is granted per category, and older Board forms still cite the earlier five-year standard, so use the current form. An autonomous NP prescribes, controlled substances included, without a physician on paper.
Physician assistants in Virginia
PAs are licensed by the Board of Medicine and practise on a patient care team under a written or electronic practice agreement with a patient-care-team physician (Va. Code 54.1-2952). The agreement sets scope, names an evaluation process and, under 54.1-2952.1, states which controlled substances the PA may prescribe; with that language a PA prescribes Schedule II through VI drugs, testosterone included. The physician must be available at all times for collaboration and may not collaborate with more than six PAs at once.
Two developments matter. House Bill 746 (2026 Acts, c. 418) added Va. Code 54.1-2952.01, which lets a PA with at least three years of full-time clinical experience practise within that specialty without a practice agreement after a physician attestation and a Board designation; the section carries a contingent effective date tied to Board regulations, so check whether the designation is actually being issued before you plan around it. Virginia also joined the PA Licensure Compact in 2024, but a compact privilege or endorsement licence still requires the three-year attestation, so a PA who is independent at home remains under a Virginia practice agreement until it is accepted.
Physicians and the corporate practice of medicine
Virginia has no corporate-practice-of-medicine statute, but the Supreme Court of Virginia has held that a non-professional corporation may not practise medicine, and the professional-entity statutes do the real work: a professional corporation under Va. Code 13.1-544 renders one professional service with shareholders licensed in that profession, and a professional limited liability company under 13.1-1102 must be owned by members licensed to render the services it offers. In practice the clinical entity is owned by licensees, and non-licensed partners or investors sit in a separate management services organization that supplies marketing, technology, billing and staff at fair market value and never directs clinical judgment.
So who may own the practice?
A physician may own the clinical entity outright as a PC or PLLC. An NP may also own one: the PLLC statute expressly allows a company organized for practitioners of the healing arts, advanced practice registered nurses and several other health professions, alone or in any combination, provided every member is licensed in one of those services. That is why physician-and-NP co-ownership of a single PLLC is routine in Virginia, and why an NP under a practice agreement can own the business while the physician is a contractor. The list does not name physician assistants, so a PA-owned clinical entity needs a Virginia health-care attorney’s read; many PA founders use a physician-owned clinical PLLC with a PA-owned MSO instead.
Virginia telehealth rules for a remote hormone practice
Licensure and patient location. Care delivered to a patient located in Virginia is practice in Virginia, and there is no telehealth-only registration for out-of-state clinicians. The one exemption, Va. Code 54.1-2901 A 35, lets a physician, PA or NP licensed elsewhere provide continuity of care by telemedicine to a current patient only after an in-person examination within the previous 12 months, which does not help a new practice. Virginia had not joined the Interstate Medical Licensure Compact as of this writing, so out-of-state physicians apply to the Board of Medicine by endorsement. Virginia is a Nurse Licensure Compact state, but the compact covers the RN licence only; the APRN licence and any practice agreement are Virginia-specific. Physicians should also budget for the annual Birth-Related Neurological Injury Compensation Program assessment.
Establishing the relationship. The Board of Medicine’s Guidance Document 85-12 accepts telemedicine as a way to establish the practitioner-patient relationship when the standard of care is met. It expects the practitioner to verify the patient’s identity and location, disclose credentials and the limits of the telemedicine model, obtain informed consent, keep records to the in-person standard, and provide for emergencies, follow-up and in-person referral. A questionnaire-only or text-and-email encounter is not an adequate evaluation, so hormone intake in Virginia is built around a live audio-video visit.
Controlled substances and the bona fide relationship. Va. Code 54.1-3303 allows a prescription only within a bona fide practitioner-patient relationship: the practitioner has obtained a medical or drug history, informed the patient of the drug’s benefits and risks, performed an appropriate examination “either physically or by the use of instrumentation and diagnostic equipment through which images and medical records may be transmitted electronically,” and arranged any needed follow-up. Within that relationship a practitioner may prescribe Schedule II through VI drugs by telemedicine, consistent with federal requirements, and for Schedule II through V drugs (testosterone is Schedule III) the prescriber must maintain a Virginia practice or be able to refer the patient to a Virginia-licensed practitioner for any in-person examination the standard of care requires. The 2025 amendments also recognize store-and-forward relationships under tighter conditions; for a new testosterone patient, plan on the live video exam, and confirm the current federal telemedicine position before the first prescription.
Registrations, the PMP and e-prescribing. Virginia does not issue a separate controlled-substance registration to individual prescribers (the Board of Pharmacy’s registration is for facilities that stock drugs), so a prescriber needs the Virginia licence, any practice agreement and a DEA registration tied to a Virginia practice address. Every Virginia-licensed prescriber must be registered with the Prescription Monitoring Program under Va. Code 54.1-2522.1. The mandatory query is narrower than in many states: until July 1, 2027 it applies before a new opioid course expected to last more than seven consecutive days, and after that before a benzodiazepine or opiate course expected to last more than 90 days. Testosterone does not trigger the statutory query, but a PMP check at intake and at each renewal is the standard-of-care practice. Likewise, the e-prescribing mandate in Va. Code 54.1-3408.02 covers opioids, not testosterone; compounding pharmacies nonetheless expect EPCS for a Schedule III injectable, so treat certified EPCS as the baseline.
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Entity options, registered agent and Virginia taxes
Clinical entities are filed with the State Corporation Commission. Physicians and NPs most often form a PLLC (the SCC asks for proof of licensure), physicians sometimes a PC, and any MSO an ordinary LLC. Every entity names a registered agent with a Virginia street address. Typical figures to confirm: articles for about $100 and a $50 annual registration fee due by the last day of the anniversary month for an LLC or PLLC; a stock PC pays an annual fee scaled to authorized shares.
Virginia has no franchise or margin tax. The corporate income tax is a flat 6 percent and applies only to entities taxed as corporations; a partnership or disregarded entity passes income to the owner’s return, where the top individual rate is 5.75 percent. The elective pass-through entity tax was written for taxable years 2021 through 2025 and a 2026 extension bill was pending at the time of writing, so ask a Virginia CPA whether the election is open for your first year. The Virginia-specific line item is BPOL, the local Business, Professional and Occupational License tax levied by nearly every city and county on gross receipts, not profit. Professional services are capped by statute at $0.58 per $100 of gross receipts, rates vary widely by locality, and most require a licence within 30 to 75 days of opening with renewal by March 1. Confirm with the commissioner of the revenue for your locality.
Labs and pharmacy in Virginia
Virginia is not one of the states that restricts direct-access laboratory testing, as far as public statutes show, and Va. Code 54.1-2409.4 requires any practitioner who orders a test to give the patient a copy of the results on request. For a cash-pay hormone clinic the clinic-ordered model is still the right one: the practice opens an account with a national laboratory, orders baseline and follow-up panels under the prescriber’s name, the patient walks into a draw site near home, and results flow into the EHR. NPs and PAs order labs within their scope.
Pharmacy is the Virginia-specific check. A pharmacy outside the state that ships compounded testosterone or other Schedule II through VI drugs to Virginia patients must hold a nonresident pharmacy registration under Va. Code 54.1-3434.1: it names a pharmacist-in-charge licensed in Virginia and submits a current home-state inspection report that, for a compounder, shows compliance with USP chapters 795, 797 and 800. A 503B outsourcing facility registers separately under 54.1-3434.5. Confirm any pharmacy’s Virginia registration on the Department of Health Professions licence lookup before routing the first prescription, and keep a Virginia-based 503A compounder as a backup.
Virginia at a glance
| Item | Virginia (confirm with the Boards or counsel) |
|---|---|
| NP practice authority | Reduced; practice agreement with a patient-care-team physician (max six NPs per physician); Schedule II–VI as the agreement lists; autonomous practice after 3 years / 5,400 hours with attestation |
| PA model | Practice agreement with a patient-care-team physician (max six PAs); Schedule II–VI as the agreement states; 2026 pathway to practise without an agreement after 3 years, contingent effective date; PA Compact member |
| Corporate practice of medicine | No statute, but professional-entity laws require licensee ownership; PLLC may combine physicians and APRNs; PA ownership needs counsel; MSO for non-clinical owners |
| Telehealth registration | None; Virginia licence required; continuity-of-care exemption only after an in-person exam within 12 months; not an IMLC state as of this writing; NLC member (RN level) |
| In-person exam before prescribing | Not required; bona fide relationship under 54.1-3303 may be formed by audio-video exam; Schedule II–V prescriber needs a Virginia practice or in-person referral path; federal rules apply |
| State controlled-substance registration | Not required for individual prescribers (DEA registration at a Virginia address) |
| PMP check | Mandatory registration; statutory query only for opioid courses over 7 days (benzodiazepine/opiate over 90 days from July 2027); testosterone check is best practice; e-prescribing mandate covers opioids |
| Direct-to-consumer labs | No state restriction identified; clinic-ordered labs are the model |
| State tax | No franchise tax; corporate 6%; individual top 5.75%; PTET extension pending; local BPOL gross-receipts tax up to $0.58 per $100 for professional services |
The 12-week Clinic In A Box map applied to Virginia
Clinic In A Box™ is a private, 1-on-1, done-with-you 12-week build led by an operator-mentor who runs active telemedicine clinics in the US, Colombia and Australia. Virginia items land in the weeks shown.
- Weeks 1–4, Foundation. Niche and patient avatar (Virginia’s military and federal workforce around Hampton Roads and Northern Virginia is a natural hormone-optimization audience); ownership model settled with counsel; entity filed with the SCC and registered agent named; Virginia licence confirmed or endorsement started; patient-care-team physician identified and the practice agreement drafted with testosterone and Schedule VI hormones named, or the autonomous-practice application filed if the 5,400 hours are in; DEA registration, NPI and PMP account checked; HIPAA framework, BAAs, and an EHR with EPCS, PMP integration and Virginia telemedicine consent language.
- Weeks 5–8, Operations. Intake and informed consent built to Guidance 85-12 (identity and location verification, credentials disclosure, emergency and in-person referral plan); the 54.1-3303 bona fide relationship checklist embedded in the visit template; PMP review at intake and each renewal; lab account opened and Virginia draw sites mapped; compounding pharmacies verified on the DHP licence lookup; cash-pay service menu, subscription option and payment processing live.
- Weeks 9–12, Launch. Patient acquisition for Northern Virginia, Richmond, Hampton Roads, Charlottesville and Roanoke (Google Business where eligible, referrals, organic search); soft launch and first patients seen; revenue and retention tracking; a 90-day roadmap including the BPOL licence, the SCC annual fee, the practice-agreement review and the hours log toward autonomous practice.
By week 12 the practice has a compliant Virginia entity, a signed practice agreement or autonomous-practice authorization, a configured EHR, lab and pharmacy relationships, a priced service menu and its first patients. Read the telemedicine hormone clinic compliance guide for the national layer under these Virginia rules, and how to start a telemedicine hormone clinic for the full sequence. Virginia NPs can start with the nurse practitioner practice startup program page; physicians should read the physician telemedicine practice launch program page. The investment is $10,000 for two hours a week of direct work plus messaging between sessions; details are on the Clinic In A Box™ program page.
Frequently asked questions
Can a nurse practitioner open a telemedicine hormone clinic in Virginia without a physician?
Yes, once the NP qualifies for autonomous practice: three years of full-time clinical experience (5,400 hours) under a practice agreement, a physician attestation and Board authorization for the NP’s category. Before that, the NP may still own the practice through a PLLC but needs a practice agreement that names testosterone and the other hormones the NP will prescribe. Confirm current requirements with the Boards of Nursing and Medicine.
Does Virginia require an in-person visit before prescribing testosterone by telehealth?
No state rule requires one. Va. Code 54.1-3303 allows the bona fide practitioner-patient relationship to be established with an examination performed through equipment that transmits images and records electronically, which a live audio-video visit satisfies, and permits Schedule II through VI prescribing by telemedicine consistent with federal law. For a Schedule III drug like testosterone the prescriber must maintain a practice in Virginia or have a referral path to a Virginia-licensed clinician for any in-person exam the standard of care calls for. Federal telemedicine prescribing rules also apply.
Do I need a Virginia controlled-substance registration in addition to my DEA number?
No. Virginia does not register individual prescribers for controlled substances; the Board of Pharmacy’s registration is for facilities and entities that stock scheduled drugs. A prescriber needs the Virginia licence, any required practice agreement, a DEA registration tied to a Virginia address and a Prescription Monitoring Program account. Confirm with the Department of Health Professions before applying for anything extra.
Can I treat Virginia patients from another state?
Only with a Virginia licence. The continuity-of-care exemption in Va. Code 54.1-2901 covers current patients examined in person within the past 12 months, which does not fit a new telemedicine relationship. Virginia was not an Interstate Medical Licensure Compact member as of this writing, so physicians apply by endorsement; NPs need a Virginia APRN licence and a practice agreement even with a multistate RN licence; PAs can use the PA Licensure Compact privilege but remain under a Virginia practice agreement until the three-year attestation is accepted.
Request your free info session
The next step is a free 30-minute info session covering your credential, your Virginia licensing and practice-agreement situation, your timeline and whether this is the right vehicle. Call 844-734-2112 or use the form below.