Yes: a nurse practitioner, physician assistant or physician can open a cash-pay telemedicine hormone practice in North Carolina, but North Carolina is a restricted-practice state and the structure has to be right before the first patient. The gating items are a collaborative practice agreement with a primary supervising physician for NPs (a supervisory arrangement or team-based registration for PAs), joint regulation by the Board of Nursing and the Medical Board, a professional-entity law that controls who may own a medical practice, a North Carolina license for anyone treating North Carolina patients, and Medical Board telemedicine policy that allows video-first care when the standard of care is met. This is a 2026 planning summary, not legal advice; confirm every point with the North Carolina Board of Nursing, Medical Board, Board of Pharmacy and counsel, because rules change.
North Carolina practice authority: who can run and own a telemedicine hormone practice
Nurse practitioners in North Carolina
North Carolina is a restricted practice state for nurse practitioners. An NP may perform medical acts, including prescribing, only under a written collaborative practice agreement (CPA) with a primary supervising physician who holds an active North Carolina license, with approval to practice issued jointly by the Board of Nursing and the Medical Board under 21 NCAC 36 .0800. Full practice authority bills, known as the SAVE Act (Senate Bill 537 and House Bill 514 in the 2025–2026 session), had not passed as of this writing; a state-court lawsuit challenging the CPA mandate was filed in September 2026 and is pending. Plan on a collaborating physician.
The CPA lists, for each practice site, the drugs, devices, treatments, tests and procedures the NP may prescribe, order and perform, plus a plan for emergencies. Both parties keep a signed copy, review it at least annually with a dated signature sheet, and run a written quality-improvement process: meetings at least monthly for the first six months and at least every six months after that, documented for the boards. The rules set no distance or on-site requirement, so a remote collaborator is common; confirm current rules with the Board of Nursing. If the agreement ends, medical acts stop until a new one is in place.
For a hormone practice the key detail is controlled substances. An NP may prescribe Schedules II through V as established in the CPA, with the NP’s DEA number and the supervising physician’s name on every prescription. Testosterone is Schedule III, so the CPA should name it expressly along with refill limits; verify the current Schedule III refill and supply limits under 21 NCAC 36 .0809 before building your protocol.
Physician assistants in North Carolina
PAs are licensed by the Medical Board. The traditional model is a signed supervisory arrangement with a primary supervising physician, monthly meetings for the first six months and at least every six months thereafter, and controlled-substance prescribing within the physician’s written instructions. Session Law 2025-37 added a second path: a team-based practice PA with more than 4,000 hours of clinical experience as a licensed PA and more than 1,000 hours in the specialty may register with the Medical Board and practice without a filed supervisory arrangement. The catch for a startup is that a team-based setting must be majority-owned by physicians, with at least one North Carolina-licensed physician meaningfully involved in care in the same clinical area, so a PA-founded clinic generally will not qualify on its own and most PA founders still use the supervisory route. Confirm the status of the implementing rules with the Medical Board.
Physicians and the corporate practice of medicine
North Carolina enforces the corporate practice of medicine through the Professional Corporations Act (Chapter 55B) and the Medical Board’s position statement on practice ownership. In general only licensees may hold shares in a professional corporation or membership in a PLLC, non-licensees may not employ physicians to practice medicine, and payments to non-licensees tied to patient fees are treated as fee-splitting, and the Board has called out straw ownership. A physician typically forms a PC or PLLC, obtains a certificate of registration from the Medical Board before filing with the Secretary of State, and places non-clinical partners in a separate management services organization under a fair-market-value agreement. A 2025 bill tightening MSO rules stalled, but have counsel paper any MSO.
So who may own the practice?
A physician may own it outright. Under G.S. 55B-14(c) a physician and a nurse practitioner may co-own a professional entity for medical and related services, and nurses, including NPs, may combine for nursing and related services; many NC NPs run their own practice as a nursing entity with a CPA physician who is not an owner. The Medical Board states that a PA and an NP may not own a professional entity together, and a PA-owned practice may not hire physicians to practice medicine for it. Which model fits, and which board certifies the entity, is a question for a North Carolina health-care attorney before you file anything.
North Carolina telehealth rules for a remote hormone practice
Licensure and patient location. The Medical Board’s telemedicine position statement (5.1.4, amended March 2024) deems the practice of medicine to occur where the patient is located, so anyone regularly treating North Carolina patients by telemedicine should hold a North Carolina license, though residence is not required. There is no telehealth registration for out-of-state practitioners. Physicians licensed elsewhere can use the Interstate Medical Licensure Compact, which North Carolina joined effective January 1, 2026. The Nurse Licensure Compact covers the RN license only; an NP still needs North Carolina APRN approval and a CPA.
Establishing the relationship. The Board holds telemedicine to the same standard of care as an in-person visit. An appropriate evaluation is expected before diagnosing or treating, and it need not be in person if the technology is sufficient; a diagnosis based solely on a static online questionnaire is not acceptable. Position Statement 4.1.1 on contact with patients before prescribing applies to every prescription. The Board expects a complete record, documented informed consent covering the risks, limitations, alternatives and benefits of the telemedicine encounter, and a follow-up and emergency plan.
Controlled substances and registrations. Testosterone is Schedule III, so each prescriber needs a DEA registration tied to a North Carolina address. North Carolina has no separate state controlled-substance registration or permit, but every DEA registrant must enroll in the Controlled Substances Reporting System (NC CSRS) within 30 days of obtaining or renewing DEA authority. The STOP Act’s mandatory 12-month-history check covers targeted controlled substances, meaning Schedule II and III opioids and narcotics, before the first prescription and every three months after; testosterone is not an opioid, so it appears to fall outside the mandatory check, though checking CSRS for every controlled prescription is sound practice. Federal telemedicine rules for controlled substances have been extended and revised repeatedly, so confirm the current federal position before prescribing. The STOP Act also mandates e-prescribing of targeted controlled substances, so certified EPCS is a baseline.
See the full 12-week program →
Entity options, registered agent and North Carolina taxes
Clinicians choose between a professional corporation under Chapter 55B and a PLLC under Chapter 57D; both need a certificate of registration from the relevant licensing board (the Medical Board for physician entities; confirm which board certifies a nursing entity) before the Secretary of State will file them, and each files an annual report. Any MSO is an ordinary LLC. Every North Carolina entity needs a registered agent with a physical North Carolina street address, not a P.O. box.
North Carolina taxes individuals at a flat 3.99 percent for 2026, with legislation signed in July 2026 stepping the rate down in later years, so a pass-through PLLC owner pays personal income tax on practice profit. The corporate income tax is 2 percent for 2026 and 2027 and scheduled to phase to zero in 2030. The franchise tax ($1.50 per $1,000 of net worth, $200 minimum) applies to entities taxed as corporations, including S corporations, and generally not to a default pass-through PLLC. Treat these as typical figures to confirm with a North Carolina CPA.
Labs and pharmacy in North Carolina
North Carolina is not on the exclusion lists the national laboratories publish for their consumer-ordered programs, so direct-to-consumer and practitioner-ordered testing are both workable; lab policies vary, so confirm with the one you use. In a cash-pay hormone model the clinic orders the panel under its own account, the patient walks into a nearby draw site, and results flow back into the EHR.
The pharmacy detail that trips new practices up is the out-of-state permit. Under G.S. 90-85.21A a pharmacy outside North Carolina must hold a North Carolina Board of Pharmacy permit before serving a North Carolina patient, and a compounding applicant must show a home-state or NABP inspection within the prior twelve months demonstrating USP compliance. Ask any pharmacy for its North Carolina permit number before routing the first prescription, and keep a North Carolina-based 503A compounder as a backup.
North Carolina at a glance
| Item | North Carolina (confirm with the board or counsel) |
|---|---|
| NP practice authority | Restricted; CPA with a primary supervising physician; joint NCBON/NCMB approval; SAVE Act not passed as of 2026 |
| PA model | Supervisory arrangement filed with the Medical Board, or team-based registration (4,000+ hours, physician-majority-owned setting) |
| Corporate practice of medicine | Strong; licensee-owned PC or PLLC with board certificate; physician–NP co-ownership allowed; MSO for non-clinical partners |
| Telehealth registration | None; North Carolina license required; IMLC for physicians from 2026; NLC covers RN only |
| In-person exam before prescribing | Not required when technology meets the standard of care; federal controlled-substance rules apply |
| State controlled-substance registration | None; DEA registration plus mandatory NC CSRS enrollment |
| PDMP check | Mandatory for Schedule II–III opioids and narcotics; recommended for all controlled prescriptions |
| Direct-to-consumer labs | Generally available; lab policies govern |
| State tax | Flat 3.99% personal income tax (2026); corporate rate 2% phasing to zero; $200 minimum franchise tax for corporate-taxed entities |
The 12-week Clinic In A Box map applied to North Carolina
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 North Carolina items land in the weeks shown.
- Weeks 1–4, Foundation. Niche and patient avatar; ownership model (physician-owned entity, physician–NP co-ownership, NP nursing entity or MSO) settled with counsel; board certificate obtained, entity filed and registered agent named; North Carolina license or APRN approval confirmed and any multi-state pathway started; supervising physician identified, CPA or supervisory arrangement submitted; DEA registration, NC CSRS enrollment and NPI; HIPAA framework, BAAs, and an EHR with EPCS and North Carolina consent language.
- Weeks 5–8, Operations. Intake and telemedicine consent finalized; quality-improvement meeting cadence calendared with the signature sheet template; lab account opened and North Carolina draw sites mapped; compounding pharmacies vetted by North Carolina permit number; Schedule III protocol and refill limits written into the CPA; cash-pay service menu, subscription option and payment processing live.
- Weeks 9–12, Launch. Patient acquisition for the Triangle, Charlotte, the Triad and rural counties (Google Business where eligible, referrals, organic search); soft launch and first patients seen; revenue and retention tracking; a 90-day roadmap including the annual CPA review, annual report and state tax calendar.
By week 12 the practice has a compliant North Carolina entity, an active collaboration, 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 North Carolina rules, and how to start a telemedicine hormone clinic for the full sequence. North Carolina 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 North Carolina without a physician?
No. North Carolina requires a collaborative practice agreement with a primary supervising physician before an NP may perform medical acts or prescribe, approved jointly by the Board of Nursing and the Medical Board. An NP can own the business as a nursing entity or co-own with a physician, but a collaborating physician, the quality-improvement meetings and an annual review are part of the model. Confirm current SAVE Act status with the Board of Nursing.
Does North Carolina require an in-person visit before prescribing testosterone by telemedicine?
The Medical Board expects an appropriate evaluation before treating, and it need not be in person if the technology is sufficient to meet the in-person standard of care; a questionnaire-only diagnosis is not acceptable. Testosterone is a federally controlled Schedule III drug, so federal telemedicine prescribing rules also apply and have changed several times; confirm the current federal position and Position Statement 4.1.1 before prescribing.
Do I need a North Carolina controlled-substance registration in addition to my DEA number?
No separate state registration or permit exists as of 2026. You need a DEA registration tied to your North Carolina practice address, the relevant North Carolina license or approval, and NC CSRS enrollment within 30 days of DEA issuance or renewal. For NPs the CPA must authorize the controlled substances you prescribe. Confirm with the Medical Board.
Can I treat North Carolina patients from another state?
Only with a North Carolina license and, for NPs and PAs, a North Carolina collaboration or supervisory arrangement. The Medical Board treats care as occurring where the patient is located and offers no telehealth registration. Physicians licensed elsewhere can apply through the Interstate Medical Licensure Compact, live in North Carolina from 2026; NPs apply to the Board of Nursing directly.
Request your free info session
The next step is a free 30-minute info session covering your credential, your North Carolina licensing and collaboration 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.