Yes: a nurse practitioner, physician assistant or physician can open a cash-pay telemedicine hormone practice in Pennsylvania once four gating items are handled. CRNPs practice under a written collaborative agreement with a physician (a prescriptive-authority agreement names a collaborating physician plus at least one substitute, so two physician signatures in practice); PAs file a written agreement with the medical board; a strict corporate-practice-of-medicine doctrine controls who may own the clinical entity; and anyone treating a patient located in Pennsylvania needs a Pennsylvania license, with the medical board’s initial-physical-exam rule for controlled substances shaping the testosterone protocol. This is a 2026 planning summary, not legal advice; confirm every point with the Pennsylvania State Board of Nursing, State Board of Medicine and counsel, because rules change.
Pennsylvania practice authority: who can run and own a telemedicine hormone practice
Nurse practitioners in Pennsylvania
Pennsylvania is a reduced practice state. A CRNP is certified by the State Board of Nursing and practices under a written collaborative agreement with a physician holding a current Pennsylvania license; full-practice bills have been introduced in successive sessions and had not become law as of this writing. Prescribing adds a second layer: the CRNP applies to the Board for prescriptive authority approval (advanced pharmacology coursework, commonly cited as 45 hours within five years), and the prescriptive authority collaborative agreement must name the collaborating physician, the CRNP’s specialty, the drug categories and limits, and at least one substitute physician. The agreement is reviewed at least every two years and the Board is notified when it changes or ends; read the current 49 Pa. Code Chapter 21, Subchapter C with your collaborator.
For a hormone practice the controlled-substance limits matter most: with the authority written into the agreement, a CRNP may prescribe Schedule II for up to 30 days and Schedule III and IV, which covers testosterone, for up to 90 days, under the CRNP’s own DEA registration and NPI. Pennsylvania does not cap the number of CRNPs a physician may collaborate with, as commonly read; confirm with the Board.
Physician assistants in Pennsylvania
Acts 78 and 79 of 2021 modernized PA practice, with implementing regulations finalized in 2025. The written agreement with a supervising physician is effective when filed with the State Board of Medicine (or Osteopathic Medicine) rather than after pre-approval, with roughly one in ten agreements audited. One physician may supervise up to six PAs, up from four, with waivers for good cause; countersignature is limited to the first 12 months after graduation or in a new specialty. Prescribing follows the written agreement, with Schedule II generally limited to 30 days and Schedules III and IV to 90 days, as commonly summarized. Pennsylvania is not in the PA Licensure Compact.
Physicians and the corporate practice of medicine
Pennsylvania’s corporate practice of medicine doctrine dates to a 1938 Supreme Court decision and is still live law: a general business corporation may not practice medicine or employ physicians to do so. A physician typically forms a professional corporation under 15 Pa.C.S. Chapter 29 or a restricted professional company (the Pennsylvania form of a PLLC), and since Act 170 of 2016 every owner of a professional entity rendering medicine must generally hold that license. Non-physician partners sit in a separate management services organization under a fair-market-value agreement that leaves clinical judgment, records and fees with the physician entity. Employed clinicians also get help from Act 74 of 2024, which makes most new non-compete covenants longer than one year unenforceable for physicians, CRNPs, PAs and CRNAs from January 1, 2025; earlier agreements are untouched, so review any existing contract with counsel.
So who may own the practice?
A physician may own it outright. A PA generally cannot own the medical entity alone and works inside a physician-owned entity, with any business interest held through an MSO. For a CRNP the honest answer is that Pennsylvania law is unsettled: nursing is not on the state’s list of restricted professional services, so a CRNP can form an ordinary LLC for a nursing practice that contracts with a collaborating physician, but some Board of Medicine language casts doubt on a CRNP owning what is in substance a medical practice. Have a Pennsylvania health-care attorney set the model in writing before you file anything.
Pennsylvania telehealth rules for a remote hormone practice
Licensure and patient location. A practitioner must hold a Pennsylvania license to treat a patient located in Pennsylvania, in person or by telehealth, and there is no separate telehealth registration. Act 42 of 2024 (the Telemedicine Act) defines telemedicine across synchronous, asynchronous and remote-monitoring care and requires insurers to cover it at the in-person standard of care from 2025–2026; for a cash-pay practice its value is confirming that telemedicine to that standard is recognized practice. Pennsylvania fully implemented the Interstate Medical Licensure Compact and the Nurse Licensure Compact on July 7, 2025; the NLC covers the RN license only, so a CRNP still needs Pennsylvania certification, prescriptive authority approval and a collaborative agreement.
Establishing the relationship and the exam question. No Pennsylvania statute requires an in-person visit before telemedicine care generally. The quirk is 49 Pa. Code § 16.92, the State Board of Medicine’s controlled-substance rule: before a physician prescribes a controlled substance, an initial medical history is taken and an initial physical examination is conducted (heart, lungs, blood pressure and the body functions related to the complaint), unless emergency circumstances justify otherwise. An exam by another licensed provider within the preceding 30 days may be relied on; the only telehealth exception, added in December 2024, covers opioid treatment programs. Testosterone is Schedule III, so a Pennsylvania hormone practice built on physician or PA prescribing typically includes an in-person intake, a partner clinic that performs the exam within the 30-day window, or a hybrid first visit; whether the same wording binds CRNPs under Board of Nursing rules is a question for counsel. Document telemedicine informed consent and HIPAA notices; Pennsylvania has no stand-alone telemedicine consent statute as commonly read, but the general informed-consent standard applies.
Controlled substances and registrations. Pennsylvania does not require a separate state controlled-substance registration for prescribers; the DEA registration tied to a Pennsylvania practice address and the professional license are the credentials. Federal telemedicine rules for controlled substances have been revised repeatedly, so confirm the current federal position before prescribing. The PA PDMP (ABC-MAP, Act 191 of 2014) must be queried the first time a patient is prescribed any controlled substance by that prescriber, for every opioid or benzodiazepine, and whenever abuse is suspected, so every new testosterone patient gets a baseline query. Act 96 of 2018 requires electronic prescribing of all Schedule II through V controlled substances, with narrow exceptions, so an EHR with certified EPCS is a baseline.
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Entity options, registered office and Pennsylvania taxes
Physicians file a professional corporation or a restricted professional company with the Department of State; restricted professional companies pay an annual registration fee per Pennsylvania-resident licensed member (several hundred dollars each). A CRNP nursing practice generally files a standard LLC, and any MSO is an ordinary LLC. Pennsylvania uses a registered office rather than a registered agent: a Pennsylvania street address or a filed Commercial Registered Office Provider. Since 2025 every entity files a $7 annual report (LLCs by September 30, corporations by June 30), with dissolution for missed reports starting in 2027.
Pennsylvania has a flat 3.07 percent personal income tax, a corporate net income tax of 7.49 percent for 2026 scheduled to fall to 4.99 percent by 2031, and no state franchise or business privilege tax. The local layer is what surprises new owners: municipal earned income tax (commonly around 1 percent), local business privilege or mercantile taxes in some municipalities, and in Philadelphia the Business Income and Receipts Tax (gross-receipts plus net-income components, with the former $100,000 exclusion gone as of tax year 2025) alongside the Net Profits Tax. Treat these as typical figures to confirm with a Pennsylvania CPA who knows your municipality.
Labs and pharmacy in Pennsylvania
Pennsylvania is one of the restricted states for consumer lab testing. The Clinical Laboratory Act requires diagnostic tests to be ordered by a licensed practitioner, a 1960s-era regulation bars laboratories from advertising to the public (a 2023 Senate bill to lift it stalled in the House), and several national consumer-testing programs list Pennsylvania among the states they cannot serve directly. The clinic-ordered model works: the clinic opens its own account with a national laboratory, orders the panel under the clinician’s license, and the patient walks into a Pennsylvania draw site. Do not plan on patients arriving with self-ordered labs.
On pharmacy, Pennsylvania has required out-of-state pharmacies to register with the State Board of Pharmacy as nonresident pharmacies since 2015 before shipping to Pennsylvania patients. Ask any compounding pharmacy for its Pennsylvania nonresident registration before routing the first prescription, confirm it accepts electronic controlled-substance prescriptions, and keep a Pennsylvania-licensed 503A compounder as a backup. Outsourcing facilities under section 503B answer to the Department of Health rather than the Board.
Pennsylvania at a glance
| Item | Pennsylvania (confirm with the board or counsel) |
|---|---|
| NP practice authority | Reduced; collaborative agreement with a physician plus a substitute physician for prescribing; Schedule II 30 days, III–IV 90 days; no independent practice as of 2026 |
| PA model | Written agreement effective on filing with the medical board; up to six PAs per physician; countersignature limited to first 12 months |
| Corporate practice of medicine | Strict; physician-owned professional corporation or restricted professional company; MSO for non-clinical ownership |
| Telehealth registration | None; full Pennsylvania license required; IMLC and NLC fully implemented July 7, 2025; NLC covers RN only |
| In-person exam before prescribing | No general telehealth bar; Board of Medicine § 16.92 requires an initial physical exam before controlled substances, or one by another provider within 30 days |
| State controlled-substance registration | None; DEA registration only |
| PDMP check | Mandatory on first controlled prescription to a patient, every opioid or benzodiazepine, and on suspicion; e-prescribing of Schedule II–V required |
| Direct-to-consumer labs | Restricted; practitioner order required; clinic-ordered model works |
| State tax | 3.07% flat personal income tax; 7.49% corporate net income tax (2026); local earned income and business taxes; Philadelphia BIRT |
The 12-week Clinic In A Box map applied to Pennsylvania
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 Pennsylvania items land in the weeks shown.
- Weeks 1–4, Foundation. Niche and patient avatar; ownership model (physician-owned professional entity, CRNP nursing practice or MSO) settled with counsel; entity filed and registered office named; Pennsylvania license confirmed and any compact pathway started; collaborating physician and substitute identified and the collaborative agreement drafted, or the PA written agreement filed; DEA registration, NPI and PDMP account; HIPAA framework, BAAs, and an EHR with certified EPCS.
- Weeks 5–8, Operations. Intake and telemedicine consent built around the § 16.92 initial-exam workflow; baseline PDMP query on every new controlled prescription; two-year agreement review calendared; lab account opened and Pennsylvania draw sites mapped; compounding pharmacies vetted for nonresident registration and EPCS; cash-pay service menu, subscription option and payment processing live.
- Weeks 9–12, Launch. Patient acquisition for Philadelphia, Pittsburgh, the Lehigh Valley and the rural counties between (Google Business where eligible, referrals, organic search); soft launch and first patients seen; revenue and retention tracking; a 90-day roadmap including the municipal tax calendar.
By week 12 the practice has a compliant Pennsylvania entity, a filed agreement, 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 Pennsylvania rules, and how to start a telemedicine hormone clinic for the full sequence. Pennsylvania CRNPs 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 Pennsylvania without a physician?
No. A Pennsylvania CRNP practices under a written collaborative agreement, and prescribing testosterone requires prescriptive authority approval from the State Board of Nursing plus an agreement naming a collaborating physician and at least one substitute. A CRNP can build and operate the business, but the physician relationship is part of the model, and whether the CRNP owns the clinical entity directly or through an MSO is a question for Pennsylvania counsel.
Does Pennsylvania require an in-person visit before prescribing testosterone by telemedicine?
Not by a general telehealth statute, but the State Board of Medicine’s controlled-substance rule requires an initial medical history and physical examination before a physician prescribes a controlled substance, allowing reliance on an exam by another licensed provider within the preceding 30 days. Most Pennsylvania hormone practices therefore run an in-person or partner-performed first exam before the first testosterone prescription. Federal telemedicine prescribing rules also apply; confirm both before prescribing.
Do I need a Pennsylvania controlled-substance registration in addition to my DEA number?
No separate state registration is required for prescribers as of 2026. You need a DEA registration tied to your Pennsylvania practice address, your Pennsylvania license, a PA PDMP account for the mandatory baseline query, and an EHR that sends electronic controlled-substance prescriptions, required since 2019. Confirm with your licensing board and the Department of Health.
Can I treat Pennsylvania patients from another state?
Only with a Pennsylvania license and, for CRNPs and PAs, a Pennsylvania collaborative or written agreement; there is no telehealth registration for out-of-state practitioners. Physicians licensed elsewhere can use the Interstate Medical Licensure Compact, fully implemented in July 2025. The Nurse Licensure Compact covers the RN license only, so a CRNP still applies to the Board of Nursing for certification and prescriptive authority.
Request your free info session
The next step is a free 30-minute info session covering your credential, your Pennsylvania 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.