Yes: a licensed NP, PA or physician can open a cash-pay telemedicine hormone practice in New York, but New York is one of the more structured states to do it in. The gating items are a New York license for every clinician who treats a New York patient, the right professional entity under New York’s strict corporate-practice-of-medicine doctrine, the state’s I-STOP e-prescribing and prescription-monitoring rules for testosterone, and a direct-to-consumer lab market that is largely closed in New York. None of these stops a launch; they decide the order of the build. Everything below is current as of 2026; confirm every legal point with the NYS Education Department Office of the Professions, the NYS Department of Health and your counsel, because several New York rules carry sunset dates.
New York practice authority for NPs, PAs and physicians
Nurse practitioners
New York sits between the full- and reduced-practice categories. Under the Nurse Practitioners Modernization Act (Education Law section 6902), an NP with more than 3,600 hours of qualifying practice may practice without a written collaborative agreement or written protocols with a physician. Experienced NPs are still expected to maintain “collaborative relationships” with a physician or licensed facility and keep an attestation (Form NP-CR) on file; confirm whether that is still required. NPs below 3,600 hours practice under a written practice agreement with a collaborating physician, with protocols and periodic chart review, so a clinic in that lane budgets for the collaborator from day one.
Two things to watch. The independent-practice provision is temporary: it was set to expire July 1, 2026, and reports indicate the 2026 session extended it to July 1, 2030 rather than making it permanent, so verify the sunset before building a model that depends on it. And New York NPs hold prescriptive authority for Schedules II through V with a DEA registration, so Schedule III testosterone is within scope; confirm with the Office of the Professions.
Physician assistants
New York remains a supervision state for PAs. Under Education Law section 6542, a PA practices under the supervision of a licensed physician; supervision must be “continuous” but does not necessarily require the physician’s physical presence, which keeps a telemedicine model workable. A 2024 amendment raised the private-practice cap from four to six PAs per supervising physician at one time; confirm the current ratio. Bills to let experienced PAs practice without supervision have been introduced repeatedly and, per the latest reports, not enacted. A PA can prescribe testosterone with a DEA registration within delegated scope but cannot own the medical entity (see below), so the New York PA model is a lead-clinician role inside a physician-owned practice.
Physicians, corporate practice of medicine, and who may own
New York’s corporate-practice doctrine is among the strictest in the country. A professional corporation or PLLC formed to practice medicine must be owned and controlled entirely by New York-licensed physicians; no non-physician or business entity may hold equity, and absentee ownership is generally barred. The Attorney General and the courts have enforced this against practices controlled through management companies, and a 2025 bill (S8442) would tighten the rules on non-physician management services organizations; confirm its status. The workable structure for a non-physician founder is a physician-owned PC or PLLC that holds the clinical practice plus a separate MSO that provides non-clinical services for a fair-market-value fee, never a percentage of revenue, with clinical decisions reserved to the licensed owners.
Who may own, subject to confirmation: physicians may own a medical PC or PLLC; NPs may form a professional entity for nurse practitioner services but not a medical PC; PAs may not own the medical entity; a non-licensed investor may own only the MSO. A physician-and-NP partnership is usually built as parallel entities plus contracts rather than one shared PLLC. The credential-specific path is covered on the nurse practitioner practice startup program and physician telemedicine practice launch program pages.
Telehealth rules in New York
Licensure and patient location. New York treats telehealth as practice occurring where the patient is located, so a clinician treating a patient physically in New York needs a New York license wherever the clinician sits. New York is not a member of the Interstate Medical Licensure Compact, the Nurse Licensure Compact or the PA Licensure Compact per the latest reports (bills to join each have been introduced), and there is no general telehealth registration for out-of-state clinicians. Plan on a full New York license for every clinician who will see New York patients, and confirm with the Office of the Professions.
Standard of care. Public Health Law section 2999-cc defines telehealth broadly, lists physicians, PAs and NPs as telehealth providers, and allows any site in the United States to serve as a distant site. The standard of care is the same as in person. No New York statute requires an in-person exam before prescribing by telehealth; the boards expect a legitimate practitioner-patient relationship and an evaluation adequate to the prescription, which for hormone therapy means a documented history, labs and a synchronous video visit. Confirm with counsel.
Controlled substances and I-STOP. Testosterone is Schedule III under federal law and New York’s Public Health Law. I-STOP adds three state obligations on top of DEA rules: nearly all prescriptions must be sent electronically through an EPCS-capable, two-factor application registered with the Bureau of Narcotic Enforcement; the prescriber must check the Prescription Monitoring Program registry (via a Health Commerce System account) before prescribing any Schedule II, III or IV drug, with limited exceptions; and the practitioner must hold an Official New York State Prescription registration with the Department of Health. New York does not require a separate state controlled-substance license for individual practitioners; the Bureau’s guidance is that a professional license plus DEA registration is the requirement. Federally, DEA’s telemedicine flexibilities allow Schedule II–V prescribing without a prior in-person visit through December 31, 2026, with a permanent special-registration rule under review; check the Federal Register for what governs 2027.
Informed consent. New York’s program-specific rules (Medicaid, Office of Mental Health) require documented telehealth consent before or during the first visit. There is no single consent statute for cash-pay clinics, but counsel generally recommend a written telehealth consent at intake alongside a hormone-therapy consent.
Entity options and New York tax notes
New York clinicians form a professional service corporation (PC) or professional service limited liability company (PLLC); an ordinary LLC may not practice a licensed profession. Formation runs through two agencies: the Office of the Professions issues a Certificate of Authority confirming every member is licensed, the articles are filed with the Department of State, and a certified copy goes back to the Education Department. PLLCs also face the publication requirement: notice in two newspapers for six consecutive weeks plus a certificate of publication, which in New York City counties can cost more than the formation itself. The Secretary of State is the statutory agent for service of process; a separate registered agent is optional. Typical tax notes: an annual LLC filing fee scaled to New York-source income (no franchise tax on PLLCs); corporate franchise tax for PCs; the NYC Unincorporated Business Tax for city practices; the MTA mobility tax in the metro region. Confirm with a New York CPA.
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Labs and pharmacy in New York
Direct-to-consumer labs are largely off the table. New York is the clearest example of a state that restricts direct-access testing. Public Health Law requires that laboratory tests be performed only on the order of a licensed practitioner acting within scope, and every specimen collected in New York must be tested by a laboratory holding a New York State clinical laboratory permit issued by the Wadsworth Center. The only general exception covers tests with an FDA-cleared over-the-counter kit. The Attorney General has enforced this against DTC lab brokers, and several national “order your own labs” services do not serve New York. For a hormone practice this is manageable: the clinician orders the panels and the lab partner holds a New York permit (the major national laboratories do). Build intake so clinician review precedes the order, and never route New York patients through DTC portals. Confirm with the Wadsworth Center.
Compounding pharmacies shipping into New York. Any pharmacy outside New York that ships prescription drugs to New York patients or prescribers must be registered with the State Board of Pharmacy as a nonresident establishment under Education Law section 6808-b and 8 NYCRR 63.8; online pharmacies are expressly included. When vetting a compounding partner, ask for its New York nonresident registration number and home-state license, whether it is a 503A pharmacy or 503B outsourcing facility, and whether your EHR can e-prescribe to it, since the mandate applies to compounded controlled substances too. Confirm with the Board of Pharmacy.
The state-independent build sequence is in our guide to how to start a telemedicine hormone clinic; the compliance layer is detailed in telemedicine hormone clinic compliance.
New York at a glance
| Item | New York (confirm with NYSED / NYSDOH / counsel) |
|---|---|
| NP practice authority | Independent after 3,600+ hours (no written agreement; collaborative-relationships attestation historically required); written practice agreement below 3,600 hours; extended to July 2030 per reports, not permanent |
| PA model | Physician supervision required (continuous, not necessarily on-site); up to 6 PAs per physician in private practice per 2024 law |
| Corporate practice of medicine | Strict: medical PC/PLLC must be 100% physician-owned and controlled; MSO at fair-market value only |
| Telehealth registration for out-of-state clinicians | None; full New York license required; not in IMLC, NLC or PA Compact as reported |
| State controlled-substance license | Not required for individual practitioners (license + DEA); EPCS registration with BNE and PMP check before Schedule II–IV prescriptions required |
| Direct-to-consumer labs | Restricted; practitioner order and NY-permitted laboratory required; narrow OTC-kit exception |
| Entity | PC or PLLC via NYSED Certificate of Authority, then Department of State; newspaper publication requirement |
The 12-week Clinic In A Box map applied to New York
Clinic In A Box is a private, 1-on-1, done-with-you 12-week build with an operator-mentor who runs active telemedicine clinics in the US, Colombia and Australia. Where the New York items land:
Weeks 1–4: Foundation and infrastructure
Week 1 sets the niche and patient avatar and confirms your New York lane: NP hours against the 3,600-hour threshold, PA supervision, or physician ownership. Weeks 2–3 handle the entity: the Certificate of Authority application, the Department of State filing, the publication plan and, with a non-physician partner, the MSO structure for counsel review. Week 3 maps licensing: New York licenses for every clinician, NPI and taxonomy, DEA registration at the New York address, Official Prescription registration and the Health Commerce System account for PMP access. Week 4 builds the HIPAA framework and configures an EPCS-certified EHR registered with the Bureau of Narcotic Enforcement, with New York consents loaded into intake.
Weeks 5–8: Operations and patient systems
Week 5 builds intake with the New York lab rule designed in: clinician review before the order, no DTC portals. Week 6 sets up New York-permitted lab partners, panels and pricing. Week 7 vets compounding pharmacies for nonresident registration and e-prescribing connectivity and documents the I-STOP workflow (PMP check, two-factor EPCS) as a standard operating procedure. Week 8 prices the cash-pay menu and monthly-management subscription and configures payment processing.
Weeks 9–12: Launch and revenue
Weeks 9–10 build acquisition: a Google Business Profile where eligible, referrals from New York gyms, therapists and primary-care offices, and organic content for New York searchers. Week 11 is the soft launch and first patients with the mentor on call. Week 12 sets revenue tracking and retention and hands you a 90-day roadmap with the dates to re-check: the NP sunset, the DEA telemedicine rule and any corporate-practice legislation. Typical economics: ten hormone-optimization patients on monthly management can mean roughly $3,000–$6,000 per month recurring, and many graduates reach positive cash flow within about 60 days of their first patient. Results are never promised.
Frequently asked questions about starting a telemedicine practice in New York
Can a nurse practitioner own a telemedicine hormone clinic in New York?
An NP can form and own a professional entity for nurse practitioner services and, with more than 3,600 hours, operate it without a written collaborative agreement, subject to the collaborative-relationships requirement and the sunset date. An NP cannot own a medical PC or PLLC. Confirm with the Office of the Professions and counsel.
Does New York require a separate state controlled-substance license to prescribe testosterone?
No, per the Bureau of Narcotic Enforcement: a New York professional license plus a DEA registration is the requirement for individual practitioners. You still register an EPCS application with the Bureau, hold an Official Prescription registration, and check the PMP before each Schedule II–IV prescription. Confirm with the Bureau.
Can an out-of-state clinician treat New York patients by telehealth?
Only with a New York license. New York has no telehealth-only registration and is not in the medical, nursing or PA compacts per the latest reports. Start the application early; the Office of the Professions can take months.
Can my New York patients order their own labs through a direct-to-consumer service?
Generally no. New York requires a practitioner’s order and a New York-permitted laboratory, with a narrow exception for tests with FDA-cleared over-the-counter kits. Your clinic orders; the patient draws at a permitted lab. Confirm with the Wadsworth Center.
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