Yes: a nurse practitioner, physician assistant or physician can open a cash-pay telemedicine hormone practice in Colorado, and Colorado is one of the more workable states to do it in. The gating items are a Colorado license for anyone treating patients located in Colorado, the two-tier prescriptive authority system for NPs (provisional, then full after a 750-hour prescribing mentorship), a written collaborative agreement for PAs, a corporate practice of medicine doctrine that decides who may own a medical entity, and the Colorado Medical Board’s telehealth policy, which permits video-first care without a prior in-person exam when the standard of care is met. This is a 2026 planning summary, not legal advice; confirm every point with the Colorado Board of Nursing, the Colorado Medical Board and counsel, because rules change.
Colorado practice authority: who can run and own a telemedicine hormone practice
Nurse practitioners in Colorado
Colorado is a full practice authority state. An APRN on the Board of Nursing’s advanced practice registry diagnoses, treats and manages patients without a collaborating or supervising physician, so there is no physician-to-NP ratio to worry about. The qualifier is prescribing, which Colorado handles in two steps under C.R.S. 12-255-112. Provisional prescriptive authority (RXN-P) goes to an APRN who attests to at least three years of combined clinical work as an RN or APRN, holds the graduate degree and national certification the board requires, has completed the board’s coursework on controlled substances and prescription drugs, carries liability insurance and is on the registry. Provisional authority already covers Schedule II through V within the APRN’s role and population focus, which includes testosterone.
Full prescriptive authority (RXN) follows a 750-hour, mutually structured prescribing mentorship with a Colorado physician or an APRN holding full authority, documented in a written, signed plan that sets out how and how often the two will discuss prescribing; remote contact counts only if it is synchronous, so email alone does not. The mentor may not require payment or employment as a condition of mentoring, and the mentorship must be finished within three years of the provisional grant or the provisional authority expires. The mentor is not a supervisor and does not co-sign charts, so an RXN-P can own and run the practice from day one. The Nurse Practice Act was revised in the 2026 session and is scheduled for sunset review in 2027, so confirm the current rule text with the Board of Nursing.
Physician assistants in Colorado
Colorado replaced physician supervision with collaboration in 2023 (SB 23-083, effective August 7, 2023). A PA practices under a written collaborative agreement with a Colorado-licensed physician, podiatrist or physician group that has a regular physical presence in the state. The agreement lists the PA’s name, license number and primary practice location, describes the collaboration and performance-evaluation process, and carries both signatures. For a PA with fewer than 5,000 practice hours, or fewer than 3,000 hours in a new practice area, the agreement is a supervisory agreement that requires collaboration during the first 160 hours and a documented evaluation. Within the agreement a PA may prescribe and dispense medication, including controlled substances, within the PA’s education, experience and competency.
Physicians and the corporate practice of medicine
Colorado has a corporate practice of medicine doctrine built from the Medical Practice Act. C.R.S. 12-240-138 lets physicians practice through a professional service corporation whose shareholders are all Colorado-licensed physicians, with one carve-out: physician assistants may hold shares as long as physicians keep majority ownership. C.R.S. 12-240-121 makes it unprofessional conduct for a physician to practice as the partner, agent or employee of a person or entity not licensed to practice medicine, and a fee-splitting prohibition sits alongside it; hospitals and certain other entities have statutory exceptions. The working model is the same as in stricter states: the physician owns the clinical entity, and any non-physician partner or investor sits in a separate management services organization (MSO) that supplies marketing, technology, staff and billing under a fair-market-value agreement.
So who may own the practice?
A physician may own it outright. A PA may hold a minority stake alongside a physician majority (a 2026 bill proposing a PA-majority exception for medical-aesthetics corporations was pending at the time of writing). An NP is the interesting case: nursing practice is not the practice of medicine, so an NP with prescriptive authority can own an LLC or PLLC that delivers nursing care, including hormone management, without a physician owner; what that entity cannot do is employ physicians to practice medicine through it. Have a Colorado health-care attorney confirm the structure before filing.
Colorado telehealth rules for a remote hormone practice
Licensure and patient location. The Medical Board’s Policy 40-27 states that the practice of medicine occurs where the patient is located, so a provider must hold a Colorado license to treat a patient in Colorado. Colorado participates in the Interstate Medical Licensure Compact, which shortens the path for physicians licensed elsewhere, and in the Nurse Licensure Compact, which covers the RN license only; an APRN still needs a Colorado APRN registration and prescriptive authority.
The 2026 telehealth registration. SB 24-141 created a registration (C.R.S. 12-30-124) that lets an out-of-state provider with an active, unencumbered credential serve Colorado patients by telehealth after registering with the Department of Regulatory Agencies, designating a Colorado agent for service of process and showing no license discipline in the prior five years. Registrations opened January 1, 2026 for physicians, PAs, nursing licensees and several other professions. Registrants must follow Colorado practice standards, may not open a Colorado office or see patients in person and, as commonly summarized, may not prescribe controlled substances. The registration can therefore cover non-controlled care, but testosterone still requires a full Colorado license; read the statute and DORA’s rules before relying on it.
Establishing the relationship. Policy 40-27 treats a provider-patient relationship as established when the provider agrees to treat the patient, both identities and the patient’s location are verified, the provider’s credentials are disclosed, and informed consent for telehealth is obtained and kept in the record. The standard of care is the same as in person, a written emergency protocol is required, and prescribing based solely on an online questionnaire is not an acceptable standard of practice. No prior in-person exam is required by statute or policy for most care, as commonly read. The policy’s definition of telehealth excludes audio-only telephone, text, fax and email, so build the practice on synchronous video and confirm the current policy text, which the Board has revised since 2015.
Controlled substances and registrations. Testosterone is Schedule III, so each prescriber needs a DEA registration tied to a Colorado practice address. Colorado issues no separate state controlled-substance registration; the statute treats the prescriber’s board license as the state registration, so no second application is required as commonly read. Federal telemedicine rules for controlled substances have been extended and revised repeatedly, so confirm the current federal position on in-person evaluation before prescribing. Colorado requires every DEA-registered prescriber to maintain a PDMP account and to query it before prescribing an opioid or benzodiazepine; testosterone is not on the mandatory list as commonly read, but checking it for every controlled prescription is sound practice. Colorado also mandates electronic prescribing of Schedule II through IV drugs (since July 1, 2021 for most prescribers and July 1, 2023 for solo and rural practices, with a low-volume exception), so an EHR with certified EPCS is a baseline.
See the full 12-week program →
Entity options, registered agent and Colorado taxes
Physicians generally form a professional service corporation under C.R.S. 12-240-138 or a professional limited liability company under the Colorado LLC Act; the PLLC is widely used, but confirm with counsel that the ownership and naming rules are met. An NP nursing practice typically files an LLC or PLLC, a PA co-owning with a physician uses the physician’s entity, and any MSO is an ordinary LLC. Everything files online with the Colorado Secretary of State; every entity must keep a registered agent with a Colorado street address and file a periodic report each year in its anniversary month, a small fee (typically $25) that moves the entity to noncompliant status if missed.
Colorado taxes income at a flat rate, 4.4 percent as of 2026, with temporary reductions in some years tied to state revenue triggers; pass-through owners pay it personally unless the entity makes the state’s pass-through entity election. There is no franchise or margin tax, and professional services are generally not subject to sales tax, though Denver and a few other cities levy an occupational privilege tax on employers and employees working inside city limits. Treat these as typical figures to confirm with a Colorado CPA.
Labs and pharmacy in Colorado
Colorado is generally listed among the states that permit direct-access laboratory testing, and the national laboratories have run patient-initiated programs there since 2016; individual labs set their own menus, so confirm with the one you use. In a cash-pay hormone model the clinic orders the panel under its own lab account, the patient walks into a nearby draw site along the Front Range or in the mountain towns, and results flow back into the EHR. A 2022 state enforcement action against uncertified collection sites is a reminder that any draw site must hold proper CLIA certification.
On the pharmacy side, any out-of-state pharmacy that ships, mails or delivers drugs into Colorado under a prescription must register with the Colorado State Board of Pharmacy as a nonresident prescription drug outlet (C.R.S. 12-280-133), maintain its home-state license and file an annual report; 503B outsourcing facilities register separately. Ask any compounding pharmacy for its Colorado registration number before routing the first prescription for injectable testosterone or a non-sterile preparation, keep a Colorado-based 503A compounder as a backup, and talk through cold-chain and winter delivery windows for mountain addresses.
Colorado at a glance
| Item | Colorado (confirm with the board or counsel) |
|---|---|
| NP practice authority | Full; no collaborating physician; provisional prescriptive authority (Schedule II–V) after 3 years’ clinical work, full after a 750-hour prescribing mentorship |
| PA model | Collaborative agreement with a Colorado physician or group (SB 23-083); supervisory agreement under 5,000 practice hours; controlled substances within competency |
| Corporate practice of medicine | Yes; physician-owned PSC or PLLC; PAs may hold a minority stake; MSO for non-clinical ownership; NP nursing practice may be NP-owned |
| Telehealth registration | Yes since January 1, 2026 (C.R.S. 12-30-124); no in-person care and, as commonly read, no controlled substances; full license otherwise; IMLC and NLC member |
| In-person exam before prescribing | Not required by statute or Policy 40-27 for most care; questionnaire-only prescribing not acceptable; federal controlled-substance rules apply |
| State controlled-substance registration | No separate application; board license serves as the state registration; DEA registration required |
| PDMP check | Mandatory before opioids or benzodiazepines; account required for all DEA-registered prescribers; recommended for all controlled prescriptions |
| EPCS | Mandatory for Schedule II–IV with limited exceptions |
| Direct-to-consumer labs | Generally permitted; lab policies govern; CLIA-certified draw sites |
| State tax | Flat income tax (4.4% typical); no franchise tax; annual periodic report; local occupational privilege tax in some cities |
The 12-week Clinic In A Box map applied to Colorado
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. The Colorado items land in the weeks shown.
- Weeks 1–4, Foundation. Niche and patient avatar; ownership model (physician PSC or PLLC, NP-owned nursing practice, PA minority stake or MSO) settled with counsel; entity filed and registered agent named; Colorado license or APRN registration confirmed and any multi-state pathway started; for NPs, provisional prescriptive authority confirmed and the 750-hour mentorship plan signed; for PAs, the collaborative agreement drafted; DEA registration, PDMP account and NPI; HIPAA framework, BAAs, and an EHR with certified EPCS and Policy 40-27 consent language.
- Weeks 5–8, Operations. Intake and telehealth consent built to Policy 40-27, including identity and location verification and the written emergency protocol; lab account opened and Colorado draw sites mapped; compounding pharmacies vetted by Colorado nonresident registration; PDMP query step built into prescribing; mentorship or collaboration check-ins calendared; cash-pay service menu, subscription option and payment processing live.
- Weeks 9–12, Launch. Patient acquisition for the Front Range metros, Western Slope and resort communities (Google Business where eligible, referrals, organic search); soft launch and first patients seen; revenue and retention tracking; a 90-day roadmap including the periodic report date, the mentorship hour log and the full-authority application timeline.
By week 12 the practice has a compliant Colorado entity, 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 Colorado rules, and how to start a telemedicine hormone clinic for the full sequence. Colorado 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 Colorado without a physician?
Yes, for practice and ownership. Colorado APRNs practice without a collaborating physician and may own the clinic. Prescribing is the qualifier: an NP needs provisional prescriptive authority, which covers Schedule II through V, and must complete a 750-hour prescribing mentorship with a Colorado physician or fully authorized APRN within three years to reach full authority. The mentor is not a supervisor and cannot demand payment or employment for the role. Confirm current requirements with the Colorado Board of Nursing.
Does Colorado require an in-person visit before prescribing testosterone by telemedicine?
Colorado statute and Medical Board Policy 40-27 do not require a prior in-person exam for most care delivered by synchronous video when the standard of care is met, but prescribing on the basis of an online questionnaire alone is not acceptable. Testosterone is a federally controlled Schedule III drug, so federal telemedicine prescribing rules also apply and have changed several times; confirm the current federal position and the Board’s current policy text before prescribing.
Do I need a Colorado controlled-substance registration in addition to my DEA number?
Not as a separate application, as commonly read: Colorado treats the prescriber’s board license as the state registration. You need a DEA registration tied to your Colorado practice address, the relevant Colorado license or prescriptive authority, a PDMP account and an EPCS-capable EHR, because Colorado requires electronic prescribing of Schedule II through IV drugs. Confirm with the Colorado State Board of Pharmacy.
Can I treat Colorado patients from another state?
Since January 1, 2026 a provider with an active, unencumbered out-of-state license can register with DORA under C.R.S. 12-30-124 to deliver telehealth to Colorado patients, but registrants may not provide in-person care or open a Colorado office and, as commonly summarized, may not prescribe controlled substances. A hormone practice prescribing testosterone therefore needs a full Colorado license, which physicians can reach through the Interstate Medical Licensure Compact and APRNs through the Board of Nursing directly.
Request your free info session
The next step is a free 30-minute info session covering your credential, your Colorado licensing and prescriptive authority situation, your timeline and whether this is the right vehicle. Either way you leave with a clearer picture of what to do next. Call 844-734-2112 or use the form below.