Yes: a nurse practitioner, physician assistant or physician can open a cash-pay telemedicine hormone practice in Michigan, and the state is more workable than its “restricted” label suggests because NPs prescribe non-controlled drugs on their own and PAs work under a practice agreement rather than supervision. The gating items are a physician delegation for any controlled substance an NP prescribes (testosterone included), a practice agreement with a participating physician for PAs, a Michigan controlled-substance license from LARA on top of the DEA registration, a Michigan license for anyone treating a patient located in Michigan, and a MAPS check before most controlled prescriptions. This is a 2026 planning summary, not legal advice; confirm every point with LARA, the Michigan Board of Nursing, the Board of Medicine or Board of Osteopathic Medicine and Surgery, the Board of Pharmacy and counsel, because rules change.
Michigan practice authority: who can run and own a telemedicine hormone practice
Nurse practitioners in Michigan
Michigan is generally classed as a restricted practice state, but the restriction is narrower than in states that require a collaborative agreement for everything. Since Public Act 499 of 2016 took effect in April 2017, an RN holding a nurse practitioner specialty certification from the Board of Nursing may prescribe non-controlled drugs, order tests and make referrals without physician delegation. Controlled substances are different: MCL 333.17211a treats a Schedule 2 through 5 prescription by an NP as a delegated act of a physician, and board rules call for a written delegation signed by both parties, listing any limitations and reviewed at least annually. Controlled prescriptions carry both the NP’s and the physician’s names and DEA numbers, which is why most NPs obtain their own Michigan controlled-substance license and DEA registration; confirm the current rule text with the Board.
For a hormone practice that means testosterone, a federal Schedule III drug, needs a delegating physician on paper even though estradiol, progesterone and thyroid medication do not. Michigan publishes no hard cap on how many NPs a physician may delegate to, as far as public rules show. A bill to let NPs prescribe controlled substances independently after 1,000 hours (House Bill 4399, approved in committee in November 2025) had not become law as of this writing; plan around delegation and check its status before you file.
Physician assistants in Michigan
Public Act 379 of 2016, effective March 22, 2017, replaced supervision with a practice agreement. A PA practices under a written agreement with a participating physician covering communication and decision-making, an alternate physician when the participating physician is unavailable, each party’s duties, credential verification, signatures and a termination clause with at least 30 days’ notice. The old PA-to-physician ratio limits were removed; the only check is a reasonableness standard enforced through discipline. A PA is an independent prescriber and writes Schedule 2 through 5 drugs under the PA’s own Michigan controlled-substance license and DEA registration, so a PA-run hormone practice needs a participating physician for the agreement, not a co-signature on each testosterone prescription. Confirm the elements against the current MCL 333.17047 text.
Physicians and the corporate practice of medicine
Michigan applies a corporate practice of medicine doctrine through attorney general opinions and its professional-entity statutes rather than a single statute. In general, an entity that renders medical services must be owned by licensees: a professional corporation or a professional limited liability company, where every member and manager rendering a Public Health Code service is licensed in that service. Physicians (MD and DO), podiatrists and chiropractors may share one entity, and a physician assistant may co-own a PC or PLLC with a physician, though PAs may not organize an entity owned only by PAs. Non-licensed partners and investors sit in a separate management services organization that supplies marketing, technology, billing and staff under a fair-market-value agreement and never directs clinical judgment.
So who may own the practice?
A physician may own the clinical entity outright. A PA may co-own with a physician. The statutes do not list nurses among the professions that may co-own with physicians, so NP-owned practices in Michigan are typically a nurse-owned PLLC or LLC rendering nursing services, with a physician providing the controlled-substance delegation under a separate agreement; whether that fits a testosterone-heavy practice is a question for a Michigan health-care attorney, who may instead recommend a physician-owned clinical entity plus an NP-owned MSO. Settle the model in writing before filing anything.
Michigan telehealth rules for a remote hormone practice
Licensure and patient location. Michigan treats the patient’s location as the place of practice. The Public Health Code’s telehealth sections (MCL 333.16283 to 16285) apply to Michigan-licensed health professionals, and a 2021 bill that would have let out-of-state practitioners treat Michigan patients without a Michigan license passed the House but stalled in the Senate, so plan on a full Michigan license. Physicians licensed elsewhere can use the Interstate Medical Licensure Compact: Michigan’s membership was about to lapse on March 28, 2026, and Public Act 6 of 2026 restored it two days before the deadline, so confirm the pathway is open when you apply. Michigan is not a Nurse Licensure Compact state as of this writing (the 2025 compact bill was pending in the Senate), so an out-of-state NP applies to the Board of Nursing by endorsement for a Michigan RN license and NP specialty certification. Michigan also requires implicit-bias training for licensure and renewal; budget for it.
Establishing the relationship. Michigan’s telehealth statute, in force since March 2017, defines telehealth to include synchronous audio-video and store-and-forward technology, requires consent for treatment before a telehealth service (MCL 333.16284), and holds telehealth to the in-person standard of care. No statute requires an in-person exam first. A prescriber must refer the patient to geographically accessible services, including emergency care, when medically necessary, and must be available for follow-up care or refer the patient for it (MCL 333.16285). Build the consent, emergency-referral and follow-up language into the intake form and the visit note.
Controlled substances and registrations. Testosterone is Schedule III, so each prescriber needs a DEA registration tied to a Michigan address and, unlike many states, a separate Michigan controlled-substance license issued by LARA under MCL 333.7303. The state license renews concurrently with the professional license, a one-time opioid and controlled-substance awareness training is required (the DEA’s substance-use-disorder training can satisfy it), and it can be requested on the professional license application or after the license issues. MCL 333.16285 lets a telehealth prescriber issue a controlled substance only within scope and in compliance with the profession’s controlled-substance rules. The main one is the bona fide prescriber-patient relationship in MCL 333.7303a: before prescribing a Schedule 2 through 5 drug the prescriber must have reviewed the patient’s relevant records and completed a full assessment, including a medical evaluation conducted in person or by telehealth, kept records to accepted standards, and must provide follow-up care to monitor the drug’s efficacy or refer the patient to a primary care provider. Federal telemedicine rules for controlled substances have changed repeatedly, so confirm the current federal position before the first prescription.
MAPS. Michigan’s prescription monitoring program is the Michigan Automated Prescription System. Every licensed prescriber must register with MAPS, and before prescribing a controlled substance exceeding a three-day supply the prescriber must obtain and review a MAPS report. A monthly testosterone prescription is a 30-day supply, so a MAPS check is part of every new and renewed testosterone prescription in Michigan. Michigan also generally requires prescriptions, controlled substances included, to be transmitted electronically, with limited exceptions and waivers, so an EHR with certified EPCS and MAPS integration is the baseline.
See the full 12-week program →
Entity options, resident agent and Michigan taxes
Physicians typically file a PC or a PLLC with LARA’s Corporations Division; a PLLC rendering a Public Health Code service shows that every member is licensed in that service, which is why the ownership question comes first. A PA co-owning with a physician uses the physician’s entity; an NP nursing practice generally files a PLLC or LLC; any MSO is an ordinary LLC. Every Michigan entity names a resident agent with a Michigan street address. LLCs file an annual statement by February 15 for a small fee, and PLLCs file an annual report with a larger fee on the same date; a company formed after September 30 typically skips the first February filing. Confirm current fees with LARA.
Michigan has no franchise or margin tax. The 6 percent corporate income tax applies only to entities taxed as corporations; a partnership or disregarded entity passes income to the owner’s return at Michigan’s flat individual rate (4.25 percent for 2026), and partnerships and S corporations may elect the flow-through entity tax as a federal SALT-cap workaround. The surprise is city income tax: Detroit taxes residents at 2.4 percent and non-residents at 1.2 percent on compensation and business net profits, Grand Rapids and Saginaw at 1.5 and 0.75 percent, and roughly twenty other cities at 1 and 0.5 percent, with no state credit. Where the practice and the owner sit therefore matters. Treat these as typical figures to confirm with a Michigan CPA.
Labs and pharmacy in Michigan
Michigan restricts direct-access testing: under MCL 333.20521 a test classified by the FDA as moderate or high complexity, which covers hormone panels, may be ordered only by a physician, dentist or other person authorized by law; only waived tests run without an order. Consumer lab vendors in Michigan route orders through their own clinicians for that reason. In a cash-pay hormone model this is a non-issue: the clinic orders the panel under its own account with a national laboratory, the patient walks into a Michigan draw site, and results return to the EHR. NPs and PAs may order labs in their own name.
Pharmacy is the second Michigan-specific check. A compounding pharmacy outside Michigan that ships to Michigan patients must hold a Michigan out-of-state pharmacy license, name a Michigan-licensed pharmacist in charge, submit a recent inspection report, and, if it ships sterile preparations such as injectable testosterone, pass a National Association of Boards of Pharmacy Verified Pharmacy Program inspection every two years. It also needs a Michigan controlled-substance license to dispense controlled drugs into the state. The licensing rule (R 338.531) was amended in March 2026, so ask any pharmacy for its Michigan license numbers, look them up on LARA’s verification search before routing the first prescription, and keep a Michigan-based 503A compounder as a backup.
Michigan at a glance
| Item | Michigan (confirm with LARA, the boards or counsel) |
|---|---|
| NP practice authority | Restricted; non-controlled prescribing independent since PA 499 of 2016; Schedule 2–5 (incl. testosterone) only by written physician delegation reviewed annually; independence bill pending |
| PA model | Practice agreement with a participating physician (PA 379 of 2016); no ratio cap; PA is an independent prescriber with own CS license and DEA |
| Corporate practice of medicine | Yes, via professional-entity statutes and AG opinions; PC or PLLC owned by licensees; physician-PA co-ownership allowed; MSO for non-clinical ownership |
| Telehealth registration | None; Michigan license required for patients located in Michigan; IMLC restored by PA 6 of 2026; not an NLC state |
| In-person exam before prescribing | Not required; bona fide prescriber-patient relationship may be established by telehealth evaluation; follow-up care required; federal rules still apply |
| State controlled-substance license | Required from LARA in addition to DEA; renews with the professional license; one-time controlled-substance awareness training |
| PDMP (MAPS) check | Mandatory registration; report required before any controlled prescription over a three-day supply; EPCS generally required |
| Direct-to-consumer labs | Restricted; moderate and high complexity tests need an authorized order; clinic-ordered labs are the model |
| State tax | No franchise tax; CIT 6% for corporations only; flat individual rate; Detroit and other city income taxes; elective flow-through entity tax |
The 12-week Clinic In A Box map applied to Michigan
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 Michigan items land in the weeks shown.
- Weeks 1–4, Foundation. Niche and patient avatar; ownership model (physician PC or PLLC, PA co-ownership, NP nursing entity or MSO) settled with counsel; entity filed with LARA and resident agent named; Michigan license confirmed, compact or endorsement application started, implicit-bias training logged; delegating physician identified and the written controlled-substance delegation drafted, or the PA practice agreement signed; Michigan controlled-substance license, DEA registration, NPI and MAPS registration; HIPAA framework, BAAs, and an EHR with EPCS, MAPS integration and Michigan telehealth consent language.
- Weeks 5–8, Operations. Intake and telehealth consent built to MCL 333.16284; the bona fide relationship checklist (records review, full assessment, follow-up plan, emergency-referral language) embedded in the visit template; MAPS check automated at every testosterone prescription and renewal; lab account opened and Michigan draw sites mapped; compounding pharmacies vetted on LARA’s license lookup for out-of-state pharmacy and controlled-substance licenses; cash-pay service menu, subscription option and payment processing live.
- Weeks 9–12, Launch. Patient acquisition for the Detroit metro, Grand Rapids, Lansing, Ann Arbor and the Upper Peninsula (Google Business where eligible, referrals, organic search); soft launch and first patients seen; revenue and retention tracking; a 90-day roadmap including city income-tax registration, the February annual statement and the annual delegation review.
By week 12 the practice has a compliant Michigan entity, a signed delegation or practice agreement, a state controlled-substance license, 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 Michigan rules, and how to start a telemedicine hormone clinic for the full sequence. Michigan 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 Michigan without a physician?
Partly. Since 2017 a Michigan NP may prescribe non-controlled hormones such as estradiol, progesterone and thyroid medication and order labs without physician involvement. Testosterone and other Schedule 2 through 5 drugs still require a written physician delegation reviewed at least annually, with both names and DEA numbers on the prescription. An NP can own and run the business; the delegating physician stays in the model until the pending independence bill becomes law, and the entity structure should be set by Michigan counsel.
Does Michigan require an in-person visit before prescribing testosterone by telehealth?
No state rule requires one. MCL 333.16285 allows controlled-substance prescribing by telehealth when the prescriber is within scope and meets Michigan’s controlled-substance rules, and the bona fide prescriber-patient relationship in MCL 333.7303a may be established through an evaluation conducted by telehealth, provided records are reviewed, a full assessment is documented and follow-up care is arranged. Federal telemedicine prescribing rules for controlled substances also apply and have changed several times, so confirm the current federal position.
Do I need a Michigan controlled-substance license in addition to my DEA number?
Yes. Michigan is one of the states that licenses prescribers separately: MCL 333.7303 requires anyone who prescribes controlled substances in Michigan to hold a controlled-substance license from LARA, renewed concurrently with the professional license, with a one-time controlled-substance awareness training. You also need a DEA registration tied to your Michigan practice address, MAPS registration, and, for NPs, a physician delegation. Confirm the application steps with LARA’s Bureau of Professional Licensing.
Can I treat Michigan patients from another state?
Only with a Michigan license. Michigan has no telehealth registration for out-of-state practitioners, and the 2021 bill that would have created an exception did not pass the Senate. Physicians licensed elsewhere can apply through the Interstate Medical Licensure Compact, which Michigan preserved in March 2026; NPs apply to the Board of Nursing by endorsement because Michigan is not a Nurse Licensure Compact state, and still need a Michigan physician delegation for controlled substances. PAs need a Michigan license and a practice agreement with a participating physician.
Request your free info session
The next step is a free 30-minute info session covering your credential, your Michigan licensing and delegation 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.