Yes — a nurse practitioner, physician assistant or physician can open a cash-pay telemedicine hormone practice in California, but it is one of the more structured states to do it in. The gating items are practice authority (NPs have a three-tier system under AB 890; PAs work under a practice agreement), strict corporate practice of medicine rules that decide who may own the clinical entity, a California license for every clinician treating a patient located in California, and the controlled-substance stack: DEA registration, CURES registration and checks, and mandatory e-prescribing. None are blockers; they are sequencing problems. Every point below is hedged — confirm with the California Board of Registered Nursing, the Physician Assistant Board, the Medical Board of California and California counsel before you file anything, because the rules change.
California nurse practitioner practice authority for telehealth
California is usually classified as a restricted-practice state, and for most NPs the default is still practice under standardized procedures with a physician, plus a BRN furnishing number for medications. AB 890 (effective 2023, amended by SB 1451 in 2025) layered two new categories on top of that default, and the category you hold decides how your clinic can be built.
- Standard NP (standardized procedures). You practice under written standardized procedures developed with a physician and furnish drugs under BPC §2836.1. You can still own a professional nursing corporation and run a clinic this way; the physician relationship is load-bearing and belongs in the budget and the compliance file.
- 103 NP (transition to practice). After BRN certification you complete a transition-to-practice period — reported as 4,600 hours or three full-time-equivalent years of clinical practice and mentorship, completed in California within the five years before applying — then apply to the BRN for 103 certification. A 103 NP may practice without standardized procedures, but only within the group settings named in BPC §2837.103 (clinics, hospitals, medical groups, professional medical corporations and similar) that include at least one physician and surgeon — not solo.
- 104 NP (independent). After a further reported three years or 4,600 hours as a 103 NP, an NP may apply for 104 certification and practice without standardized procedures outside the §2837.103 settings, including a practice the NP owns through a nursing corporation, within the population focus of the national certification. 104 NPs are still expected to consult, refer and collaborate with physicians for emergent conditions.
NPs who furnish controlled substances need a DEA registration, an active California furnishing number and the Schedule II continuing-education course; California NPs may furnish Schedule II–V drugs, which covers Schedule III testosterone. Whether AB 890 hours must fall inside your certification population focus has been changing, so confirm the current application requirements on rn.ca.gov before you count your hours.
Physician assistants and physicians in California
PAs. Since SB 697 took effect in 2020, California PAs work under a practice agreement with the organized health care system or physician(s) rather than a named-physician delegation of services agreement. The supervising physician must be available by phone or electronic means, chart co-signature is no longer mandated, and PAs may prescribe, including controlled substances with a DEA registration. The supervision ratio was reported to rise from 1:4 to 1:8 under AB 1501, effective January 1, 2026 — confirm the enacted text of BPC §3516 with the Physician Assistant Board. A PA cannot own a medical practice outright; under the Moscone-Knox Act a PA may hold up to 49 percent of a professional medical corporation when physicians hold at least 51 percent.
Physicians. California has one of the strictest corporate practice of medicine doctrines in the country. Medical services are delivered through a professional medical corporation owned by California-licensed physicians (allied licensees — NPs, PAs, RNs and others — capped at a combined 49 percent) or by a sole-proprietor physician. Unlicensed persons and general business entities may not own the clinical entity, employ physicians to deliver care or control clinical decisions. The standard workaround is the MSO model: a management services organization owns the non-clinical assets and contracts with a physician-owned PC. Two recent laws tightened this. SB 351, signed October 2025 and effective January 1, 2026, codifies limits on private-equity and hedge-fund control of medical and dental practices — clinical judgment, records, provider hiring, payor contracting, billing and equipment decisions stay with licensees, and non-compete and non-disparagement clauses in those management contracts are barred. AB 1415, also effective 2026, extends Office of Health Care Affordability pre-transaction notice to MSOs, with regulations still developing. Confirm both with counsel before signing an MSO agreement, especially if outside capital is involved.
The practical answer on who may own: a physician may own a medical corporation; an NP (any category) may own a professional nursing corporation; a PA or NP may hold a minority stake in a physician-owned medical corporation; anyone may own an MSO that provides administrative services at fair market value. The structure you choose in week one shapes everything after it, which is why the California build in Clinic In A Box™ starts with entity and ownership before any software is bought.
California telehealth rules for a hormone practice
- License where the patient is. The Medical Board’s position is that a clinician treating a patient located in California must hold a California license (BPC §§2051–2052). California is not in the Interstate Medical Licensure Compact or the Nurse Licensure Compact and has no telehealth registration pathway for out-of-state clinicians; narrow exceptions exist for physician-to-physician consultation and certain life-threatening conditions.
- Consent. BPC §2290.5 requires the provider initiating telehealth to inform the patient and obtain verbal or written consent, documented in the record. Failing to do so is unprofessional conduct, so consent belongs in the intake flow.
- Prior examination. BPC §2242 requires an “appropriate prior examination” before prescribing. Since AB 1264 (2019), that examination need not be synchronous or in person and may be done by telehealth, provided the standard of care is met. BPC §2242.1 separately penalizes internet-only prescribing without an appropriate examination, so questionnaire-only models are a risk area.
- Controlled substances. California has no separate state controlled-substance registration beyond the DEA; instead, any California licensee holding a DEA number must register with CURES, the state PDMP, and consult it before first prescribing a Schedule II–IV drug and periodically thereafter (confirm the current interval). Federal telemedicine rules for controlled substances also apply to testosterone and continue to evolve.
- E-prescribing. Under AB 2789, nearly all prescriptions issued to a California pharmacy must be transmitted electronically (since January 1, 2022), with limited exceptions. Your EHR needs EPCS-capable e-prescribing from day one.
The compliance frame we use across states is laid out in our guide to telemedicine hormone clinic compliance; the California version adds CURES and the ownership rules above.
See the full 12-week program →
Entity options in California
California does not allow LLCs (and has no PLLC) to render licensed professional services under Corporations Code §17701.04. Clinicians form a professional corporation under the Moscone-Knox Act: a professional medical corporation for physicians, a professional nursing corporation for NPs, or a physician assistant corporation, still subject to the practice agreement. Register with the Secretary of State, name a California registered agent, file the Statement of Information, obtain any board registration or fictitious-name permit required, and set up the EIN and NPI. Typical tax notes: an $800 minimum franchise tax applies each year (first-year waivers have changed — check the Franchise Tax Board) and an S-election carries a 1.5 percent California S-corporation tax. An MSO can be an ordinary LLC or corporation because it renders no clinical services.
Labs and pharmacy in California
Labs. California is restrictive on patient-initiated testing. BPC §1246.5 lets consumers self-order only a short list (pregnancy, glucose, cholesterol, occult blood and FDA-approved over-the-counter analytes), which is why many direct-to-consumer lab platforms exclude California. That limit applies to patients ordering for themselves; a California-licensed clinician ordering hormone panels through Quest, Labcorp or a draw-site network for a patient under their care is the normal pathway. Build the lab workflow as practitioner-ordered and confirm the current statute text.
Pharmacy. Any out-of-state pharmacy shipping compounded or commercial prescriptions into California needs a nonresident pharmacy license from the Board of Pharmacy (BPC §4112), and sterile compounders need the separate nonresident sterile compounding license (BPC §4127.2). Ask every compounding partner for its California license numbers before routing a prescription, and confirm its handling of Schedule III shipments and CURES reporting.
California at a glance
| Item | California (confirm with the board / counsel) |
|---|---|
| NP authority | Restricted by default (standardized procedures); 103 NP = no standardized procedures in group settings with a physician; 104 NP = independent after a further 3 years |
| PA model | Practice agreement (SB 697); supervision ratio reported 1:8 from 2026; up to 49% ownership of a medical corporation |
| CPOM | Strict; physician-owned professional medical corporation or MSO + PC; SB 351 and AB 1415 effective 2026 |
| Telehealth registration | None; full California license required; not in IMLC or NLC |
| State CSR required? | No separate state registration; CURES registration and checks mandatory; e-prescribing mandatory |
| DTC labs | Patient self-ordering limited (BPC §1246.5); practitioner-ordered labs standard |
The 12-week Clinic In A Box map applied to California
Weeks 1–4. The entity decision comes first: professional medical corporation, professional nursing corporation, or an MSO-plus-PC structure with ownership percentages that survive Moscone-Knox and the 2026 laws. NPs map their AB 890 category and any standardized-procedure arrangement; PAs draft the practice agreement. Licensing is confirmed, the NPI is set up, CURES registration follows the DEA number, and the EHR is chosen for EPCS e-prescribing and §2290.5 consent capture, with HIPAA policies and BAAs executed in the same block.
Weeks 5–8. Intake is built around California’s requirements: documented telehealth consent, an appropriate prior examination by video, practitioner-ordered lab panels, and a prescribing workflow that checks CURES and routes to pharmacies holding California nonresident licenses. The service menu is priced for cash pay with a monthly-management model.
Weeks 9–12. Soft launch and first California patients, Google Business where eligible, referral and organic acquisition, revenue tracking and the 90-day roadmap, including whether to add a second state. For the full sequence before the California specifics, our guide on how to start a telemedicine hormone clinic lays it out. For the credential-specific build, see the nurse practitioner practice startup program or the physician telemedicine practice launch program.
Frequently asked questions
Can a California nurse practitioner own a telemedicine hormone clinic without a physician?
An NP of any category may own a professional nursing corporation, but only a 104 NP may practice in it without standardized procedures. A 103 NP can drop standardized procedures only inside a group setting that includes a physician, and a standard NP needs standardized procedures and a physician relationship regardless of ownership. Confirm your category with the BRN.
Do I need an in-person visit before prescribing testosterone in California?
California law does not require a synchronous in-person visit; BPC §2242 allows the appropriate prior examination to occur by telehealth if the standard of care is met. Testosterone is Schedule III, so you also need a DEA registration, a CURES check, EPCS e-prescribing and compliance with current federal telemedicine rules for controlled substances. Confirm with your board and counsel.
Can I treat California patients if I am licensed in another state?
Generally no. The patient’s location controls, California is not in the IMLC or NLC, and there is no telehealth registration shortcut. Plan on a full California license, which can take months, and build that into weeks 1–4.
Does SB 351 stop me from using an MSO in California?
Not by itself. SB 351 targets private-equity and hedge-fund control of medical and dental practices and codifies that clinical and key operational decisions stay with licensees; a properly drafted MSO agreement at fair market value remains the standard California structure. It is a recent law with regulations still developing, so have California counsel review any MSO agreement.
Request your free info session
The next step is a free 30-minute info session: your credential, your AB 890 category or practice agreement, your ownership structure and your California timeline, and whether this is the right vehicle. Call 844-734-2112 or use the form below.