Yes: a nurse practitioner, physician assistant or physician can open a cash-pay telemedicine hormone practice in Maryland, and for NPs it is one of the friendlier states on the East Coast. The gating items are a Maryland license for anyone treating a patient located in Maryland, a Maryland controlled dangerous substances (CDS) registration on top of the DEA number, a collaboration agreement filed with the Board of Physicians for PAs, an 18-month mentor declaration for NPs new to certification, the telehealth rules in Health Occupations Title 1, Subtitle 10, and a lab law that keeps consumer-ordered testing off the table. This is a 2026 planning summary, not legal advice; confirm every point with the Maryland Board of Nursing, Board of Physicians, Office of Controlled Substances Administration, Board of Pharmacy and counsel, because rules change.
Maryland practice authority: who can run and own a telemedicine hormone practice
Nurse practitioners in Maryland
Maryland is a full practice authority state. The Nurse Practitioner Full Practice Authority Act of 2015 (Chapter 468) repealed the old physician attestation, and a certified registered nurse practitioner (CRNP) now diagnoses, treats and prescribes under the Board of Nursing with no physician agreement, chart co-signature or required meetings (Health Occupations 8-302, COMAR 10.27.07). The one transition rule is the mentor: an applicant who has never been certified as a nurse practitioner in Maryland or any other state names, on the certification application, a Maryland-licensed CRNP or physician with at least three years of clinical experience who is available for consultation as needed for 18 months from the date the Board receives the application. There is no written agreement, no ratio and no filing beyond the name; ask the Board how the rule applies if you are moving a certification in from another state.
A Maryland CRNP may prescribe Schedule II through V controlled dangerous substances, so testosterone (federal Schedule III) is within scope without a physician on paper. What the NP needs is the state CDS registration described below and a DEA registration tied to a Maryland practice address, in that order.
Physician assistants in Maryland
Maryland rewrote the PA framework with the Physician Assistant Modernization Act of 2024 (SB 167, Chapter 919, and HB 806, Chapter 920), effective October 1, 2024. The delegation agreement is gone. A PA practices under a collaboration agreement written by the PA together with an individual physician or physician group, now called a patient care team physician. The PA gives the Board of Physicians notice of the executed agreement and each physician on it; no Board approval is required, a copy stays at the practice setting, and the Board may audit it. Delegation agreements active on October 1, 2024 continue as collaboration agreements.
Two points matter for a remote practice: collaboration does not require the physician’s physical presence if the physician is reachable electronically, and a patient care team physician may collaborate with up to eight PAs at once, up from four. Board approval of advanced duties is no longer required for a PA with more than 7,000 hours of experience. The COMAR 10.32.03 rewrite was still moving through adoption in 2025, so read the current regulation alongside the statute. Prescribing, controlled substances included, runs through the agreement with the same DEA, Maryland CDS and PDMP obligations as any other prescriber, so name testosterone and the other hormones the PA will manage rather than relying on a general clause.
Physicians and the corporate practice of medicine
Maryland has no single corporate-practice-of-medicine statute, and its courts have never adopted the doctrine in so many words, but it is real: commonly cited Maryland guidance reads the professional corporation statute, the Health Occupations Article and Attorney General and Board of Physicians positions together to mean that an ordinary corporation cannot practice medicine through employed physicians, and that a practice entity must be owned by physicians or related licensed professionals unless it is itself licensed to deliver care, as a hospital is. The Board and the Attorney General have said the same of an LLC owned by non-licensed persons. The result is the familiar two-entity model: a licensee-owned clinical entity delivers care, and any non-licensed partner or investor sits 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. An NP may own an NP practice, and because Maryland NPs practice without a physician agreement an NP-owned hormone clinic is a clean structure; whether it is a professional corporation or an LLC is a counsel question discussed below. A PA-owned clinic is the hardest case, and many PA founders use a physician-owned clinical entity with a PA-owned MSO instead. Maryland’s professional corporation law is a single-profession statute, so a physician and an NP generally cannot share one PC. Have a Maryland health-care attorney set the model in writing before you file anything.
Maryland telehealth rules for a remote hormone practice
Licensure and patient location. Maryland’s telehealth subtitle (Health Occupations 1-1001 through 1-1006, enacted in 2020) treats care delivered to a patient located in Maryland as practice in Maryland, and the practitioner must be licensed, certified or otherwise authorized in the state. There is no general telehealth registration for out-of-state clinicians; the 2021 bills that would have created one did not pass, and the 2022 out-of-state pathway covers behavioral health only. Maryland is an Interstate Medical Licensure Compact member through at least 2030 and a Nurse Licensure Compact state, but the nursing compact covers the RN license only; CRNP certification is applied for separately with the Board of Nursing. PAs apply to the Board of Physicians by endorsement.
Establishing the relationship and consent. Section 1-1003 sets the baseline for every telehealth visit: verify the patient’s identity, disclose the practitioner’s name, contact information and license type, obtain oral or written consent, and perform a clinical evaluation appropriate to the presenting condition before treating or prescribing. The evaluation may be synchronous or asynchronous, but questionnaire-only prescribing is barred and the standard of care is the same as in person. The Board of Physicians’ rules in COMAR 10.32.05, amended effective September 15, 2025 to track the Preserve Telehealth Access Act of 2025, have historically called for a synchronous audio-video evaluation before a prescription, so build hormone intake around a live video visit regardless of which board you answer to. The 2025 Act also made audio-only telehealth permanent in the statutory definition and ordered a Health Care Commission report by December 2026, so expect further rule changes.
Controlled substances and the Maryland CDS registration. This is the step that catches clinicians arriving from states with no state registration. Maryland requires a CDS registration from the Office of Controlled Substances Administration (OCSA, part of the Department of Health and recently reorganized; confirm the current office name) before a practitioner prescribes, administers, dispenses or stores CDS at a Maryland practice location, and OCSA’s instructions say the state registration comes before the DEA application for that address. Typical figures to confirm: a three-year registration for about $120, a one-time two-hour continuing-education requirement on CDS prescribing, and proof of Prescription Drug Monitoring Program enrollment, since OCSA will not issue or renew a registration to a prescriber who is not in the PDMP. Testosterone is Schedule III, so this applies to every prescriber in the practice. Section 1-1003 also makes a telehealth CDS prescriber subject to every federal and state limitation on CDS; Maryland’s limits on Schedule II opiates for pain do not touch a hormone practice, but the federal telemedicine rules for controlled substances have been revised repeatedly, so confirm the current federal position before the first prescription.
PDMP and e-prescribing. Maryland’s PDMP runs on CRISP, the state-designated health information exchange. Health-General 21-2A-04.2 requires a prescriber to query PDMP data before initially prescribing an opioid or benzodiazepine and every 90 days while the course continues, and to document the review; testosterone is not on that list, but a PDMP check at intake and each renewal is the standard-of-care habit. Health-General 21-220 requires CDS to be prescribed electronically (in force since January 1, 2022, enforced from January 1, 2023), so an EHR with certified EPCS is a baseline, not an upgrade.
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Entity options, resident agent and Maryland taxes
Entities are filed with the State Department of Assessments and Taxation (SDAT). Maryland has no professional limited liability company as a distinct entity type. A physician practice is most often a professional corporation under Corporations and Associations Title 5, which issues stock only to persons licensed in that single profession; an LLC may render professional services if every member is licensed, which is the form many NP practices use; any MSO is an ordinary LLC. Confirm with counsel which form your board will accept, because the compliance sources disagree on the LLC question. Every entity names a resident agent (Maryland’s term for a registered agent) with a physical Maryland street address. Typical figures to confirm: articles for about $100 ($150 filed online with expediting), and an annual report and personal property return due April 15 with a flat $300 fee, required even if the entity owns no property.
Maryland has no franchise or margin tax for a medical practice. The corporate income tax is 8.25 percent and applies only to entities taxed as corporations; a pass-through entity sends income to the owner’s return, where the state rate runs from 2 to 5.75 percent. The Maryland-specific line item is the county income tax: every county and Baltimore City levies a piggyback income tax on residents, roughly 2.25 to 3.3 percent for 2026 (3.2 percent in Montgomery, Howard, Baltimore County and Baltimore City), so the effective top rate for a Maryland-resident owner is closer to 9 percent than 5.75. An elective pass-through entity tax (8.75 percent for individual members) lets the entity pay that tax for the federal deduction. Treat these as typical figures to confirm with a Maryland CPA.
Labs and pharmacy in Maryland
Maryland restricts direct-to-consumer laboratory testing. Under Health-General Title 17 and COMAR 10.10.06 a medical laboratory may perform a test only on the order of a physician, nurse practitioner, physician assistant or another person authorized by statute, with narrow exceptions for FDA-approved home tests and health-fair screening, and the national consumer-ordering programs generally list Maryland among the states where a resident cannot complete an order. A 2019 amendment to Health-General 17-215 loosened the old ban on advertising laboratory tests to consumers but did not create a right to self-order. For a cash-pay hormone clinic none of this is a problem: the clinic opens an account with a national laboratory, the practitioner orders baseline and follow-up panels, and the patient walks into a draw site near home.
Pharmacy is the second Maryland-specific check. A pharmacy outside the state that ships, mails or delivers prescription drugs to a Maryland patient must hold a nonresident pharmacy permit from the Maryland Board of Pharmacy under Health Occupations 12-404: it operates under its home-state law and Maryland’s rules, discloses how it ships into Maryland, staffs a toll-free line and, for sterile compounding such as injectable testosterone, shows a recent inspection report and USP 797 compliance. The Board has disciplined out-of-state compounders that shipped into Maryland without a permit, so verify every pharmacy’s Maryland permit on the Board’s lookup before routing the first prescription, and keep a Maryland-based 503A compounder as a backup.
Maryland at a glance
| Item | Maryland (confirm with the Boards, OCSA or counsel) |
|---|---|
| NP practice authority | Full since 2015; no collaborative agreement; first-time applicants name a mentor (CRNP or physician, 3+ years) for 18 months; Schedule II–V prescribing |
| PA model | Collaboration agreement with a patient care team physician (2024 Modernization Act, effective October 1, 2024); notice to the Board of Physicians, no approval; up to eight PAs per physician; physician may be remote |
| Corporate practice of medicine | Implied rather than express; licensee-owned PC or all-licensee LLC delivers care; single-profession PC rule; MSO for non-clinical owners |
| Telehealth registration | None; Maryland license required for a patient located in Maryland; IMLC member through 2030; NLC covers RN only, CRNP certification separate |
| In-person exam before prescribing | Not required by statute; identity verification, disclosure, consent and clinical evaluation required; no questionnaire-only prescribing; plan on live audio-video; federal controlled-substance rules apply |
| State controlled-substance registration | Yes: Maryland CDS registration from OCSA before the DEA registration; about $120 per three years; PDMP enrollment and a one-time two-hour CDS CE required |
| PDMP check | Mandatory before an initial opioid or benzodiazepine prescription and every 90 days after; testosterone check is best practice; electronic prescribing of CDS mandatory |
| Direct-to-consumer labs | Restricted; practitioner-ordered labs only, with narrow exceptions |
| State tax | No franchise tax; corporate 8.25%; individual 2–5.75% plus county income tax of roughly 2.25–3.3%; elective PTE tax; $300 annual report due April 15 |
The 12-week Clinic In A Box map applied to Maryland
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. Maryland items land in the weeks shown.
- Weeks 1–4, Foundation. Niche and patient avatar (the federal, military and biotech workforce around Washington, Baltimore and Fort Meade is a natural hormone-optimization audience); ownership model settled with counsel; entity filed with SDAT and resident agent named; Maryland license confirmed or endorsement started, mentor named for a first CRNP certification; for PAs, the collaboration agreement drafted and noticed to the Board; PDMP enrollment, CDS continuing education, the Maryland CDS application and then the DEA registration, in that order; NPI; HIPAA framework, BAAs, and an EHR with certified EPCS and Maryland telehealth consent language.
- Weeks 5–8, Operations. Intake and consent built to Section 1-1003 (identity verification, practitioner disclosure, consent captured, live video evaluation documented); PDMP review at intake and each renewal; lab account opened and Maryland draw sites mapped with the practitioner-ordered workflow; compounding pharmacies verified for a Maryland nonresident permit; cash-pay service menu, subscription option and payment processing live.
- Weeks 9–12, Launch. Patient acquisition for Montgomery and Prince George’s counties, Baltimore, Annapolis, Frederick and the Eastern Shore (Google Business where eligible, referrals, organic search); soft launch and first patients seen; revenue and retention tracking; a 90-day roadmap including the April 15 annual report, the CDS renewal date, the collaboration-agreement review and, for a new NP, the end of the 18-month mentor period.
By week 12 the practice has a compliant Maryland entity, a filed collaboration agreement or independent CRNP certification, state and federal controlled-substance registrations, 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 Maryland rules, and how to start a telemedicine hormone clinic for the full sequence. Maryland 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 Maryland without a physician?
Yes. Maryland has been a full practice authority state since 2015, and a CRNP diagnoses, treats and prescribes Schedule II through V drugs with no collaborative agreement, chart review or physician filing. A first-time certification names a mentor, a Maryland CRNP or physician with at least three years of experience, available for consultation for 18 months. The NP still needs a Maryland CDS registration and a DEA registration before prescribing testosterone. Confirm current requirements with the Maryland Board of Nursing.
Does Maryland require an in-person visit before prescribing testosterone by telehealth?
No state statute requires one. Health Occupations 1-1003 requires identity verification, practitioner disclosure, consent and a clinical evaluation appropriate to the condition, and bars prescribing on a questionnaire alone; the Board of Physicians’ regulations have expected a synchronous audio-video evaluation before a prescription, so plan on a live video visit. Testosterone is Schedule III, so the federal telemedicine prescribing rules also apply and have changed several times; confirm the current federal position and COMAR 10.32.05 before prescribing.
Do I need a Maryland controlled-substance registration in addition to my DEA number?
Yes. Maryland requires a Controlled Dangerous Substances registration from the Office of Controlled Substances Administration for any practitioner who prescribes, administers, dispenses or stores CDS at a Maryland practice location, obtained before the DEA registration for that address. Expect a three-year registration for about $120, proof of PDMP enrollment on CRISP and a one-time two-hour CDS continuing-education requirement. Confirm current fees with OCSA before applying.
Can I treat Maryland patients from another state?
Only with a Maryland license and, for a prescriber, a Maryland CDS registration and a DEA registration tied to a Maryland address. Maryland has no telehealth registration for out-of-state practitioners outside a narrow behavioral-health pathway. Physicians licensed elsewhere can use the Interstate Medical Licensure Compact; compact-state nurses still apply to the Board of Nursing for CRNP certification; PAs apply to the Board of Physicians and file a collaboration agreement with a Maryland patient care team physician.
Request your free info session
The next step is a free 30-minute info session covering your credential, your Maryland licensing and registration situation, your timeline and whether this is the right vehicle. Call 844-734-2112 or use the form below.