Yes: a nurse practitioner, physician assistant or physician can open a cash-pay telemedicine hormone practice in Minnesota, and the state is workable for an NP-owned clinic once a transition period is behind you. The gating items are 2,080 hours of collaborative practice before an NP or PA practises on their own paper, the Professional Firms Act that decides who may own the clinic, a Minnesota licence (or, for physicians only, an interstate telehealth registration) for anyone treating a patient located in Minnesota, and a pharmacy-law wrinkle in Minn. Stat. 151.37 that ties a Schedule II–IV prescription such as testosterone to an in-person examination pathway. This is a 2026 planning summary, not legal advice; confirm every point with the Minnesota Board of Nursing, Board of Medical Practice, Board of Pharmacy and counsel, because rules change.
Minnesota practice authority: who can run and own a telemedicine hormone practice
Nurse practitioners in Minnesota
Minnesota is a full practice state with a front-loaded transition. Under Minn. Stat. 148.211, subd. 1c, a nurse practitioner who qualifies for APRN licensure must practise at least 2,080 hours within a collaborative agreement, a mutually agreed plan for the working relationship with one or more physicians (licensed in Minnesota or another state) or, since a 2026 amendment, one or more APRNs with at least three years of practice, in each case experienced with the same or similar medical problems; the NP files written evidence of the hours with the Board of Nursing. The 2026 law (ch. 115, art. 11, effective August 1, 2026 per the Board’s summary) dropped the old hospital-or-integrated-setting requirement but added subd. 1d: an NP whose first 2,080 hours are outside primary care or mental health must complete them where APRNs and physicians work together. A hormone-focused clinic is likely to be read that way, so a brand-new NP should expect to log the transition hours inside such a setting; confirm the Board’s interpretation first.
After the hours are documented, the NP practises independently with no agreement and no ratio. Under Minn. Stat. 148.235, subd. 7a, an APRN may prescribe legend and controlled substances, with the DEA registration filed with the Board. Testosterone is Schedule III under Minn. Stat. 152.02, subd. 4, and within scope, subject to the examination rule below. An APRN licence requires a Minnesota RN licence first; Minnesota is not a Nurse Licensure Compact state as of this writing (compact bills had not passed), so a multistate RN licence from elsewhere does not substitute.
Physician assistants in Minnesota
Minnesota rewrote PA practice in 2020, replacing supervision with a practice-level model. Minn. Stat. 147A.02, para. (c), still requires a newly qualified PA to practise 2,080 hours within a collaborative agreement with one or more physicians, in a hospital or integrated clinical setting where PAs and physicians work together. A 2025 bill proposed dropping the setting requirement; the Board’s January 2026 attestation form still recites the current text, so check the statute before assuming any change.
Once licensed, a PA practises under a practice agreement kept at the practice level (Minn. Stat. 147A.09): no named supervising physician and no ratio, but a licensed physician within the same clinic, hospital or health system who knows the PA’s practice must review the agreement annually, with a record kept for the Board. For a PA-owned telemedicine clinic that means a physician affiliated with the clinic, usually a contractor, performs that review. Prescribing authority under 147A.185 covers legend and controlled substances with DEA compliance. Minnesota enacted the PA Licensure Compact in 2024 (Minn. Stat. 147A.35); confirm whether compact privileges are being issued yet.
Physicians and the corporate practice of medicine
Minnesota applies a common-law corporate practice of medicine doctrine dating to 1933, and the practical rulebook is the Minnesota Professional Firms Act, Minn. Stat. ch. 319B. A clinical entity that elects professional-firm status may issue ownership interests only to licensed professionals authorized to render at least one of the firm’s services, to other professional firms, or to a few narrow holders such as a licensee-controlled voting trust (319B.07); governance follows ownership. A non-licensed partner or investor therefore sits in a separate management services organization that supplies technology, marketing, billing and staff at fair market value and never directs clinical decisions. Two cautions: the fee-splitting prohibition in Minn. Stat. 147.091, subd. 1(p), makes percentage-of-revenue management fees risky, and 2025–2026 bills (HF 2779 / SF 2939) would have codified the doctrine and restricted MSO arrangements. They had not passed as of this writing, but the direction is tighter, so have a Minnesota health-care attorney structure any MSO.
So who may own the practice?
Minn. Stat. 319B.40 lets professionals licensed in medicine, as physician assistants, in registered nursing (the statutory range that includes APRN licensure under 148.211) and several other fields form a professional firm alone or in any combination. A physician, an NP or a PA may therefore each own the clinical entity outright, or share it. Ownership does not change the practice rules: an NP owner still needs the collaborative agreement for the first 2,080 hours, and a PA owner still needs a practice agreement with an annual physician review. Anyone who is not a licensee owns the MSO, not the firm.
Minnesota telehealth rules for a remote hormone practice
Licensure and patient location. Care delivered to a patient located in Minnesota is practice in Minnesota. Physicians have one shortcut: under Minn. Stat. 147.032 a physician licensed without restriction in another state may treat Minnesota patients by interstate telehealth after registering annually with the Board of Medical Practice ($100 initial application, $75 annual registration, per the statute), provided the physician never opens an office, meets patients in person or takes patient calls in Minnesota and has never had a licence revoked or restricted anywhere. Minnesota is also an Interstate Medical Licensure Compact member. There is no equivalent for NPs: the Board of Nursing treats nursing practice as occurring where the patient is located, so an out-of-state NP needs a Minnesota RN and APRN licence. PAs need a Minnesota licence or, once operational, a compact privilege.
Establishing the relationship and the standard of care. Minn. Stat. 147.033 states that a physician-patient relationship may be established through telehealth and that telehealth is held to the same standards as in-person care. The Minnesota Telehealth Act, Minn. Stat. 62A.673, subd. 2(h), defines telehealth as real-time two-way interactive audio and visual communication; until July 1, 2027, audio-only also qualifies for a scheduled appointment where the standard of care can be met that way. No telehealth-specific informed-consent statute was located, so build consent to the ordinary standard (nature and limits of a remote exam, privacy, emergency instructions, in-person referral) and document it.
Controlled substances: the Minnesota examination rule. This item shapes a Minnesota hormone clinic’s intake. Minn. Stat. 151.37, subd. 2(d), provides that a prescription for a Schedule II–IV controlled substance (Minn. Stat. 152.02, subds. 3 to 5) is not valid unless based on a documented patient evaluation, including an examination, adequate to establish a diagnosis and identify underlying conditions and contraindications. Paragraph (e) spells out how that is met: an in-person examination by the prescriber (now or previously), by another prescriber in the same group or clinic, by a consultant to whom the patient was referred, or by the referring practitioner where a consultant prescribes by telehealth. The only drugs for which the statute expressly accepts a telehealth examination are PDE5 inhibitors and medications for opioid use disorder; testosterone is Schedule III and is not on that list. Workable models: an in-person baseline visit with the prescriber or a same-group colleague in Minnesota, or a consult model in which an examining Minnesota practitioner refers to the telemedicine prescriber. Estradiol, progesterone, clomiphene, thyroid and other non-controlled hormones are unaffected and can follow a video visit. Confirm the reading with the Board of Pharmacy and counsel, and apply the federal telemedicine prescribing rules as well.
Registrations, the PMP and e-prescribing. Minnesota issues no separate state controlled-substance registration; the Minnesota licence plus a DEA registration covering Minnesota practice is the set. Every Minnesota-licensed prescriber with a DEA registration must maintain a Prescription Monitoring Program account (Minn. Stat. 152.126, subd. 6(c)); the mandatory query covers only opioids, but a PMP review at intake and renewals is standard practice. Minn. Stat. 62J.497 has required electronic prescribing since 2011, and compounding pharmacies expect EPCS for a Schedule III injectable.
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Entity options, registered office and Minnesota taxes
Clinical entities are filed with the Minnesota Secretary of State. The usual choice is an LLC under ch. 322C whose articles elect to operate under Minn. Stat. 319B.01 to 319B.12 and list the professional services the firm will render; a professional corporation under ch. 302A is the alternative. Every entity names a registered office with a Minnesota street address; a registered agent is optional but useful for an out-of-state owner. Typical figures to confirm: $155 to file articles online ($135 by mail) and a free annual renewal due by December 31. Before furnishing services the professional firm also files with each board that regulates its services (319B.11), roughly $100 initially and a $25 annual report due January 1.
Minnesota has no franchise or margin tax on pass-through entities, but it has a minimum fee: a partnership, multi-member LLC or S corporation pays nothing until Minnesota property, payroll and sales reach $1,280,000 (2026 schedule), then $260 and up; a single-member LLC on the owner’s return is exempt. C corporations pay the 9.8 percent corporate franchise tax and individual rates run from 5.35 to 9.85 percent, so most clinic owners stay pass-through. The elective pass-through entity tax was extended through tax year 2027 in May 2026; ask a Minnesota CPA whether the election helps.
Labs and pharmacy in Minnesota
Minnesota is not among the states that restrict direct-access laboratory testing, as far as the public record shows. For a cash-pay hormone clinic the clinic-ordered model is still the right one: the practice opens an account with a national laboratory, orders baseline and follow-up panels under the prescriber’s name, the patient walks into a draw site near home, and results flow into the EHR. NPs and PAs order labs within their scope.
Pharmacy is the Minnesota-specific check. A pharmacy outside the state that ships compounded testosterone or any other prescription drug to Minnesota residents must hold a Minnesota pharmacy licence under Minn. Stat. 151.19, subd. 1, which involves an inspection (or a home-state inspection report from the prior 24 months) and a toll-free number for Minnesota patients. Confirm any pharmacy’s licence on the Board of Pharmacy’s online lookup before routing the first prescription, and keep a Minnesota-based 503A compounder as a backup. Because the 151.37 examination rule governs the validity of the prescription itself, expect a licensed pharmacy to decline a Schedule II–IV order that does not meet it.
Minnesota at a glance
| Item | Minnesota (confirm with the Boards or counsel) |
|---|---|
| NP practice authority | Full after 2,080 hours under a collaborative agreement (physician or 3-year APRN); non-primary-care hours in an APRN-and-physician setting; controlled substances with DEA; no agreement afterward |
| PA model | 2,080 hours under a collaborative agreement in a hospital or integrated setting, then a practice-level agreement reviewed annually by a physician in the same clinic; no ratio; PA Compact enacted 2024 |
| Corporate practice of medicine | Common-law doctrine plus Professional Firms Act (ch. 319B); only licensees own the clinical firm; physicians, NPs and PAs may own alone or together; fee-splitting rule limits MSO fees |
| Telehealth registration | Physicians: 147.032 interstate telehealth registration (no Minnesota office or in-person contact) or IMLC licence; NPs: Minnesota RN + APRN licence, not an NLC state; PAs: licence or compact privilege |
| In-person exam before prescribing | Not for non-controlled drugs; for Schedule II–IV drugs including testosterone, 151.37 subd. 2 ties validity to an in-person examination pathway; telehealth exam accepted only for PDE5 inhibitors and OUD medications |
| State controlled-substance registration | Not required; Minnesota licence plus DEA registration |
| PMP check | Account mandatory for every DEA-registered prescriber; statutory query only for opioids; testosterone check is best practice; e-prescribing required since 2011 |
| Direct-to-consumer labs | No state restriction identified; clinic-ordered labs are the model |
| State tax | No franchise tax on pass-throughs; minimum fee from $1.28M Minnesota receipts; corporate 9.8%; individual 5.35–9.85%; PTE election through 2027 |
The 12-week Clinic In A Box map applied to Minnesota
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. Minnesota items land in the weeks shown.
- Weeks 1–4, Foundation. Niche and patient avatar (the Twin Cities workforce and the long-drive populations of greater Minnesota are natural hormone-optimization audiences); ownership model and any MSO settled with counsel; LLC or PC filed with the professional-firm election and the board filing made; Minnesota licence, interstate telehealth registration or IMLC application in motion; collaborative agreement or hours log settled for an NP, practice agreement and physician reviewer lined up for a PA; DEA, NPI and PMP account checked; HIPAA framework, BAAs, and an EHR with EPCS, PMP integration and telehealth consent language.
- Weeks 5–8, Operations. Intake built around the 151.37 examination rule: a Minnesota in-person baseline pathway for testosterone candidates and a video-first pathway for non-controlled hormones; PMP review at intake and each renewal; lab account opened and draw sites mapped; compounding pharmacies verified on the Board of Pharmacy lookup; cash-pay service menu, subscription option and payment processing live.
- Weeks 9–12, Launch. Patient acquisition for Minneapolis–St. Paul, Rochester, Duluth, St. Cloud and Mankato (Google Business where eligible, referrals, organic search); soft launch and first patients seen; revenue and retention tracking; a 90-day roadmap covering the January 1 board report, the December 31 renewal, the PA practice-agreement review and the NP hours attestation.
By week 12 the practice has a compliant Minnesota professional firm, the right agreement or attestation on file, a configured EHR, lab and pharmacy relationships, a priced menu and its first patients. Read the telemedicine hormone clinic compliance guide for the national layer under these Minnesota rules, and how to start a telemedicine hormone clinic for the full sequence. Minnesota 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 Minnesota without a physician?
Yes, once the NP has documented 2,080 hours under a collaborative agreement with the Board of Nursing. From August 2026 the collaborator may be a physician in any state or an APRN with three years of practice, and hours outside primary care or mental health must be served where APRNs and physicians work together. An NP who already has the hours may own a professional firm and prescribe, testosterone included, with no physician on paper. Confirm current requirements with the Board of Nursing.
Does Minnesota require an in-person visit before prescribing testosterone by telehealth?
As the statute reads, yes in practical terms. Minn. Stat. 151.37, subd. 2, makes a Schedule II–IV prescription valid only when it rests on a documented evaluation including an examination, and lists in-person examinations (by the prescriber, a same-group colleague, a consultant or a referring practitioner) as the ways that requirement is met; a telehealth examination is accepted only for PDE5 inhibitors and opioid-use-disorder medications, and testosterone is Schedule III. Non-controlled hormones such as estradiol, progesterone and thyroid can follow a video visit. Confirm with the Board of Pharmacy and counsel; federal telemedicine prescribing rules also apply.
Do I need a Minnesota controlled-substance registration in addition to my DEA number?
No. Minnesota does not register individual prescribers for controlled substances. A prescriber needs the Minnesota licence (or the physician interstate telehealth registration), a DEA registration covering Minnesota practice with the number on file at the licensing board, and a Prescription Monitoring Program account, which is mandatory for every DEA-registered prescriber. Confirm with the Board of Pharmacy before applying for anything extra.
Can I treat Minnesota patients from another state?
A physician can, through a full Minnesota licence (the Interstate Medical Licensure Compact speeds this up) or the 147.032 interstate telehealth registration, which is cheaper but bars any office, in-person visit or patient phone contact in Minnesota and requires a clean licensure history. An NP must hold a Minnesota RN and APRN licence; Minnesota is not a Nurse Licensure Compact state and has no telehealth registration for nurses. A PA needs a Minnesota licence or, once operational, a PA Compact privilege. Whoever prescribes testosterone also needs the in-person examination pathway above.
Request your free info session
The next step is a free 30-minute info session covering your credential, your Minnesota licensing and agreement situation, your timeline and whether this is the right vehicle. Call 844-734-2112 or use the form below.