Yes: a nurse practitioner, physician assistant or physician can open a cash-pay telemedicine hormone practice in Florida, and Florida is one of the more workable states to do it in. The gating items are the physician relationship (most hormone-focused APRNs and every PA in Florida practice under a supervisory arrangement, because autonomous APRN registration is limited to primary care), the Health Care Clinic Act analysis for your entity, the controlled-substance rules for testosterone by telehealth, and the pharmacy permits behind any compounded medication shipped into the state. Every point below reflects public sources as of 2026 and should be confirmed with the Florida Board of Nursing, Board of Medicine, AHCA or your counsel before you file anything, because the rules change.
Florida practice authority: NP, PA and physician
Nurse practitioners in Florida
Florida is a reduced-practice state with a narrow full-practice lane. Since HB 607 (2020), an APRN can register for autonomous practice under Fla. Stat. 464.0123 if they hold an unencumbered license, show roughly 3,000 clinical hours under physician supervision within the prior five years, have graduate coursework in differential diagnosis and pharmacology, carry financial-responsibility coverage and have had no discipline in five years. The catch for a hormone clinic: autonomous practice is permitted only in “primary care practice” (family medicine, general pediatrics, general internal medicine) as defined by Board of Nursing rule. Whether hormone optimization, testosterone replacement or menopause care fits that definition has no bright-line answer from the Board, and the common reading among Florida health-law practitioners is that specialty-flavored practice still needs a supervisory protocol with a Florida-licensed physician. Plan on the protocol unless counsel says otherwise in writing.
Under a protocol (Fla. Stat. 464.012), the APRN and physician sign a written agreement describing duties and the drug therapies the APRN may manage. The Board of Nursing stopped receiving protocols in 2017; the document lives at the practice, and the supervising physician files a notice with the Board of Medicine stating how many APRNs are covered (Fla. Stat. 458.348). Florida APRNs with the required coursework may prescribe controlled substances, including Schedule III testosterone; Schedule II is capped at a seven-day supply outside psychiatry, and controlled-substance CE is required at renewal. Confirm all of it with the Board of Nursing before you sign.
Physician assistants in Florida
PAs practice under a supervising physician (Fla. Stat. 458.347). Supervision means “responsible supervision and control,” with the physician readily available by telecommunication or physically present; one physician may supervise up to ten PAs (raised from four in 2021). The physician may delegate prescribing within the physician’s practice but must notify the Department of Health on its form before delegating and whenever privileges change. Schedule II is limited to a seven-day supply; Schedule III testosterone is delegable for most practices. A PA can own a Florida entity; the practical question is how the supervising physician is papered (owner, employee or paid supervision agreement). Confirm the current form and rules with the Board of Medicine.
Physicians, corporate practice of medicine and ownership
Florida does not enforce a strict corporate-practice-of-medicine doctrine the way California, Texas or New York do; non-physicians can own entities that employ physicians, and MSO structures are common but not mandatory. What replaces CPOM in Florida is the Health Care Clinic Act (Fla. Stat. 400.990 et seq.), which requires AHCA licensure for an entity “where health care services are provided to individuals and which tenders charges for reimbursement,” unless an exemption applies. The exemption most new practices rely on is 400.9905(4)(g): an entity wholly owned by licensed health care practitioners (physicians, PAs and APRNs licensed under 464.012 are all listed), where a practitioner-owner supervises the business and is legally responsible for compliance. Agency guidance and legislative analyses have also read the Act as aimed at entities that bill third parties, with cash-only practices outside the definition, and AHCA offers a voluntary certificate of exemption. A wholly clinician-owned, cash-pay, telehealth-only entity therefore usually sits outside licensure, but a non-clinician investor, an insurance or PIP claim, or a physical Florida site can change the answer. Get counsel’s written opinion and consider filing for the certificate rather than self-determining.
Telehealth rules in Florida
Florida’s telehealth statute is Fla. Stat. 456.47; the Board of Medicine’s older telemedicine rule was repealed in 2019 in its favor. The main points for a hormone practice, each to be confirmed with the relevant board:
- Patient location. Telehealth is deemed to occur where the patient is located, so serving Florida residents means a Florida license or a Florida telehealth registration, wherever the clinician sits.
- Out-of-state telehealth provider registration. A clinician licensed elsewhere with an unencumbered, substantially similar license, no discipline in five years, a Florida registered agent and liability coverage that includes Florida patients can register with the Department of Health rather than obtain a full license. Registrants may not open a Florida office or see Florida patients in person, must link to their registrant profile from their website, and must report discipline within five business days. The registration has historically carried no state fee (a proposed $150 fee was vetoed); the registered agent is the cost.
- Standard of care and in-person exam. The telehealth standard equals the in-person standard, and a telehealth evaluation is sufficient to diagnose and treat without a separate physical exam if the evaluation itself meets that standard. Hormones off a questionnaire alone would not; a synchronous visit plus labs is the expected floor.
- Controlled substances by telehealth. Since 2022, telehealth prescribing of Schedule III, IV and V is permitted in Florida; Schedule II remains barred except for psychiatric disorders, hospital inpatients, hospice and nursing-home residents. Testosterone is Schedule III, so a compliant telehealth TRT visit can produce a valid prescription under state law. Federal DEA telemedicine rules apply on top and keep evolving.
- PDMP. Fla. Stat. 893.055 requires the prescriber (or a designee) to consult E-FORCSE before prescribing any Schedule II-V controlled substance to a patient 16 or older, with narrow exceptions (non-opioid Schedule V, hospice, documented outage). That means a documented PDMP check before every testosterone prescription; a first miss draws a citation, repeats draw discipline.
- State controlled-substance registration. Florida does not issue a separate state CSR for prescribers; Florida license plus DEA registration is the pair. DEA registrants must complete a board-approved two-hour controlled-substance prescribing course at each renewal (Fla. Stat. 456.0301); the chronic-pain prescriber designation generally does not apply to a hormone practice. Confirm with your board.
- E-prescribing. Practitioners who use an EHR must transmit prescriptions electronically (Fla. Stat. 456.42), so the EHR needs EPCS for controlled substances.
- Consent and records. The statute creates no separate telehealth consent form, but general informed-consent duties, HIPAA and Florida’s records statutes apply, and telehealth encounters must be documented to the in-person standard. A written telehealth consent naming the modality, its limits and the prescribing policy is the practical minimum.
See the full 12-week program →
Entity options in Florida
Florida clinicians choose among a standard LLC, a Chapter 621 professional limited liability company or professional service corporation, and a corporation. A Chapter 621 entity restricts members to licensees of the same profession, clean for a single-credential practice and awkward when an NP and a physician co-own; many Florida practices use an ordinary LLC instead, since the state does not force professional-entity form on medical practices and the Health Care Clinic Act is what polices ownership. Typical mechanics: a Sunbiz filing in the low hundreds of dollars, a Florida registered agent, an annual report due by May 1 with a steep late penalty, and an EIN before the bank account. Florida has no personal income tax; its 5.5% corporate income tax reaches C corporations, not pass-through LLCs or S corporations. Professional medical services are not subject to sales tax, though supplements or products may be. Treat this as typical, not advice, and confirm with a Florida CPA and counsel.
Labs and pharmacy in Florida
Florida repealed its state clinical-laboratory licensure in 2018, so labs serving Florida patients operate on CLIA certification alone, and the national reference labs plus most direct-to-patient lab platforms serve the state without a Florida-specific restriction. The practice orders the panel, the patient draws at a patient service center, and no Florida rule forces an in-person visit before labs are ordered for a telehealth patient. On the pharmacy side, compounded testosterone, injectable peptides and similar products shipped into Florida must come from a pharmacy holding a Florida nonresident pharmacy permit (Fla. Stat. 465.0156), and any sterile compounded product also requires a nonresident sterile compounding permit (Fla. Stat. 465.0158); in-state 503A pharmacies carry their own Florida permits. Ask every pharmacy partner for its Florida permit numbers before the first prescription and confirm it will fill for an out-of-state telehealth registrant if that is your pathway. The Board of Pharmacy is the authority here.
Florida at a glance
| Item | Florida (confirm with board / counsel) |
|---|---|
| NP authority | Reduced; autonomous registration exists but primary care only; hormone practice typically under supervisory protocol |
| PA model | Supervising physician, up to 10 PAs per physician; DOH notice before delegated prescribing |
| CPOM | No strict doctrine; Health Care Clinic Act licensure unless exempt (wholly clinician-owned, cash-pay) |
| Telehealth registration | Yes, for out-of-state licensees; no state fee historically; registered agent required |
| State CSR required? | No separate state CSR; DEA + license; E-FORCSE check every controlled Rx |
| Testosterone by telehealth | Schedule III allowed since 2022; Schedule II barred except narrow cases |
| DTC labs | Allowed; CLIA-only since 2018 repeal of state lab licensure |
The 12-week Clinic In A Box map applied to Florida
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 Florida items land in defined weeks.
- Weeks 1–4. Niche and patient avatar; entity choice (LLC vs Chapter 621) with the Health Care Clinic Act exemption question sent to counsel in week 1; Florida license or telehealth registration filed, registered agent appointed, NPI and DEA updated; for NPs, the supervisory protocol drafted and the physician’s Board of Medicine notice queued; for PAs, the DOH delegation form; HIPAA framework, BAAs and an EHR with EPCS and an E-FORCSE workflow.
- Weeks 5–8. Intake and telehealth consent written to Florida’s standard-of-care language; Quest, Labcorp and direct-to-patient lab accounts live; pharmacy partners vetted for Florida permits; a prescribing workflow that forces the PDMP check; cash-pay service menu, subscription model and a payment processor that accepts a hormone practice.
- Weeks 9–12. Patient acquisition for Florida metros (Google Business where eligible, referrals, organic), soft launch, first patients seen, revenue and retention tracking, and a 90-day roadmap that may add a second state.
The framework behind this page is our guide to how to start a telemedicine hormone clinic, with the compliance layer in telemedicine hormone clinic compliance. Nurse practitioners can read the credential-specific version on the nurse practitioner practice startup program page, physicians on the physician telemedicine practice launch program page. Economics, hedged: ten hormone-optimization patients on monthly management can mean roughly $3,000–$6,000 per month recurring for many practices, and many graduates reach positive cash flow within about 60 days of their first patient. Nothing is promised; the program ends with a clinic that exists.
Florida FAQ
Can a Florida nurse practitioner run a hormone clinic without a physician?
Only if the practice fits the Board of Nursing’s definition of primary care and the NP holds autonomous registration under 464.0123. Most hormone-focused practices are treated as needing a supervisory protocol. Get a written read from the Board or counsel on your service menu before launching without one.
Can I prescribe testosterone to Florida patients by telehealth?
Under Florida law, yes for Schedule III since the 2022 amendment to 456.47, provided the telehealth evaluation meets the in-person standard of care, you check E-FORCSE before each prescription, and you prescribe electronically. Federal DEA telemedicine rules also apply; confirm current federal requirements with counsel.
Do I need an AHCA Health Care Clinic license for a cash-pay telehealth practice?
Often not, if the entity is wholly owned by licensed practitioners who supervise it and it does not bill third parties, but the answer turns on ownership and billing details. AHCA offers a voluntary certificate of exemption; many practices obtain it rather than self-determine. Confirm with AHCA or counsel.
Can an out-of-state clinician treat Florida patients without a Florida license?
Yes, through the Department of Health’s out-of-state telehealth provider registration, as long as you never see Florida patients in person, keep a Florida registered agent and qualifying liability coverage, and meet the discipline-free history requirement. Verify with each pharmacy partner that it fills registrant prescriptions.