Yes: a nurse practitioner, physician assistant or physician can open a cash-pay telemedicine hormone practice in Tennessee. The gating items are a supervising physician with a written protocol for NPs and a collaborating physician for PAs (Tennessee has no independent practice for either), a corporate-practice-of-medicine rule that puts clinical ownership with physicians and, in limited combinations, PAs, a full Tennessee license for anyone treating a Tennessee patient, and a controlled-substance layer built around the CSMD database and mandatory electronic prescribing. This is a 2026 planning summary, not legal advice; confirm every point with the Tennessee Board of Nursing, Board of Medical Examiners and counsel, because rules change.
Tennessee practice authority: who can run and own a telemedicine hormone practice
Nurse practitioners in Tennessee
Tennessee is a restricted practice state for APRNs. A nurse practitioner who prescribes must have a supervising physician who, in the words of Code Section 63-7-123, controls and is responsible for the NP’s prescriptive services, and there is no transition-to-practice pathway that ends in independence. Full practice authority bills have been introduced in recent sessions, but as of 2026 none has passed; do not plan around a change.
The working document is the protocol, jointly developed, dated and signed by both and kept at the practice site. The physician must hold a current, unencumbered Tennessee license, have experience in the same area of medicine and be available for consultation at all times or name a substitute; the protocol is reviewed and updated at least every two years. Before prescribing, the NP needs a certificate of fitness and files a notice with the Board of Nursing naming the supervising physician and the formulary, updated within 30 days of any change. Tennessee sets no fixed physician-to-NP ratio.
Supervision duties are what a telemedicine founder must design around. Under Board of Medical Examiners rule 0880-06-.02 the supervising physician personally reviews at least 20 percent of the NP’s charts every 30 days, with a signed review of charts involving a controlled drug on a tighter cycle, and visits any remote site at least once every 30 days; a 2022 statutory change is commonly read to allow up to 10 of the year’s visits by HIPAA-compliant video, the rest in person. The Board has said in advisory discussions that for a telehealth NP who works from home, the remote site is the NP’s home or a site named in the protocol, so a distant supervising physician is a logistics problem. Confirm the current rule text with both boards.
For a hormone practice the key detail is controlled substances. Tennessee NPs may prescribe Schedule II through V with a DEA registration at the practice location, but Schedule II through IV drugs require either formulary authorization or the supervising physician’s approval after consultation before the first prescription, Schedule II or III opioids are limited to a non-refillable 30-day course, and a separate state law caps dispensing of any Schedule II or III drug at a 30-day supply. Testosterone is Schedule III and not an opioid, so a formulary that lists it and documents the consultation step is the usual approach; read Section 63-7-123 and Board of Nursing chapter 1000-04 with counsel first.
Physician assistants in Tennessee
PAs are licensed by the Tennessee Board of Physician Assistants, while physician-PA practice rules stay with the Board of Medical Examiners. Since 2018 the statute says collaboration rather than supervision, but the substance is similar: a written protocol jointly developed and signed with a collaborating MD or DO who holds a current, unencumbered Tennessee license, chart review on a 20-percent-every-30-days cadence, monthly visits to remote sites, and under Section 63-19-107 physician review of 100 percent of charts within 30 days whenever the PA prescribes a controlled drug under the protocol. PAs may prescribe Schedule II through V with their own DEA registration, subject to the same 30-day dispensing cap. A 2024 bill to lighten collaboration for experienced PAs stalled; confirm whether anything has moved since.
Tennessee gives PAs something NPs do not get: ownership. The Professional Corporation Act and the Revised LLC Act both allow physician assistants to hold interests in a medical professional entity in combination with licensed physicians (radiologists, pathologists and anesthesiologists excluded), and Attorney General opinions read them the same way. A PA cannot own the clinical entity alone, and a physician-PA-NP group is not automatically authorized, so a PA founder typically builds with a physician co-owner.
Physicians and the corporate practice of medicine
Tennessee follows the corporate practice of medicine doctrine through common law and statute; its 2025 reform (House Bill 979) loosened only hospital employment of certain specialists in smaller counties and did not change who may own a practice. A physician starting a cash-pay hormone clinic forms a medical professional corporation or a PLLC and owns it outright. Non-physician investors, spouses and operating partners sit in a separate management services organization supplying marketing, technology, billing and staff under a fair-market-value agreement. A pending federal bill would restrict MSO control over hiring, compensation and billing; draft the agreement conservatively.
So who may own the practice?
A physician may own it outright. A PA may co-own with a physician. An NP, as the Attorney General has put it, may not own a professional corporation or PLLC for the provision of medical services, so an NP-led Tennessee practice is typically structured as a physician-owned clinical entity plus an NP-owned MSO, or as a nursing-practice entity whose medical acts run under the physician’s protocol. Have a Tennessee health-care attorney put the model in writing before anything is filed.
Tennessee telehealth rules for a remote hormone practice
Licensure and patient location. Tennessee treats the patient’s location as the place of practice: a provider treating a patient in Tennessee needs Tennessee authority to do so. For MDs the old telemedicine-only license is history: the Board of Medical Examiners stopped issuing it, converted holders to full licenses by 2018, and the retained version carries no prescriptive authority, so a full Tennessee license is the only workable path. The Board of Osteopathic Examination still lists a telemedicine license application for DOs; confirm its narrow eligibility terms directly. The Interstate Medical Licensure Compact shortens the route to a full license for physicians licensed elsewhere. The Nurse Licensure Compact covers the RN license only; an APRN still needs Tennessee APRN licensure, a certificate of fitness and a Tennessee supervising physician. The only out-of-state exception in Section 63-1-155 is for volunteers at qualifying free clinics.
Establishing the relationship. Section 63-1-155 defines telehealth to include real-time audio, video and store-and-forward, creates the provider-patient relationship by mutual consent and communication (receiving a patient’s records alone is not enough), and holds the telehealth provider to the same standard of care as in-person practice. Neither the statute nor Board rule 0880-02-.16 requires an in-person exam before telehealth treatment; the rule instead requires identity verification, disclosure of the physician’s name, location, degree and specialty, documentation of the technology used, and referral for a physical exam when transmitted information is insufficient. The Board of Nursing’s 2024 prescribing rule applies the same logic to APRNs: document a history and physical, a supported diagnosis and a therapeutic plan, and never prescribe on a questionnaire alone. The statute carves out pain management clinics and chronic nonmalignant pain, which a hormone practice should avoid.
Informed consent. Tennessee has no single telehealth consent statute for medicine and nursing, but the mutual-consent language in Section 63-1-155 and the standard of care make a documented telehealth consent covering the technology, its limits, identity verification and emergency procedures the sensible baseline for intake.
Controlled substances and registrations. Testosterone is Schedule III, so every prescriber needs a DEA registration tied to a Tennessee practice address. Tennessee does not issue a separate controlled-substance registration to individual prescribers (the Board of Pharmacy’s registration covers pharmacies, manufacturers and distributors), but two state obligations attach instead. First, every practitioner with a DEA number who treats Tennessee patients on more than 15 days a year must register in the Controlled Substance Monitoring Database within 30 days of getting it, and a supervised NP and the supervising physician confirm their relationship there. Second, Section 53-10-310 requires a CSMD check before prescribing an opioid, benzodiazepine or Schedule II amphetamine at the start of a new episode, before each new prescription in the first 90 days and at least every six months after; testosterone is not on that list as commonly read, but checking for every controlled prescription is sound practice. Tennessee has required electronic prescribing of all Schedule II through V controlled substances since January 1, 2021, so an EHR with certified EPCS is non-negotiable. Federal telemedicine flexibilities for controlled substances are currently extended through December 31, 2026; confirm the federal position before the first prescription.
See the full 12-week program →
Entity options, registered agent and Tennessee taxes
Physicians choose between a medical professional corporation and a PLLC, both filed with the Tennessee Secretary of State and both limited to physician ownership plus the professionals the statutes allow alongside them. A PA co-owning with a physician uses that entity; an NP’s business entity or an MSO is an ordinary LLC. LLC filing and annual-report fees run $50 per member with a $300 minimum, and the annual report is due the first day of the fourth month after fiscal year-end, April 1 for most. Every Tennessee entity needs a registered agent with a physical Tennessee street address.
Tennessee has no individual tax on wages or business income; the Hall tax on investment income was fully repealed for 2021 and later. The state-level cost is the franchise and excise tax, which applies to LLCs, PLLCs and corporations even when they are pass-through entities federally: franchise tax of 0.25 percent of net worth with a $100 minimum, and excise tax of 6.5 percent of Tennessee net earnings, filed on Form FAE 170 by the fifteenth day of the fourth month after year-end. That 6.5 percent on entity earnings surprises clinicians who form an LLC without reading the fine print, so model it with a Tennessee CPA before choosing a structure. Treat these as typical figures to verify.
Labs and pharmacy in Tennessee
Tennessee has no statute restricting direct-access laboratory testing the way New York or New Jersey do, and the national laboratories’ consumer programs list Tennessee as available; lab policies govern, so confirm with the one you use. In a cash-pay hormone model the clinic orders the panel under its own lab account, the patient walks into a draw site in Nashville, Memphis, Knoxville, Chattanooga or a rural county, and results flow into the EHR.
The pharmacy detail that trips up new practices is nonresident licensing. A pharmacy outside Tennessee that dispenses to Tennessee patients must be licensed as an out-of-state pharmacy practice site by the Tennessee Board of Pharmacy, keep records of every Tennessee prescription, print a toll-free number on each label and follow the state’s counseling rules. A pharmacy compounding sterile products shipped into Tennessee, which includes injectable testosterone, must also hold a sterile compounding modifier registration backed by a home-state inspection within the past 12 months under Section 63-10-216. Ask any compounder for its Tennessee license number and modifier before routing the first prescription, and keep an in-state 503A backup.
Tennessee at a glance
| Item | Tennessee (confirm with the board or counsel) |
|---|---|
| NP practice authority | Restricted; supervising physician with written protocol; 20% chart review every 30 days, monthly site visits; Schedule II–V with formulary or consultation; no independent practice as of 2026 |
| PA model | Collaborating physician with protocol; 20% chart review, 100% review within 30 days of controlled prescriptions; physician-PA co-ownership permitted |
| Corporate practice of medicine | Enforced; physician-owned PC or PLLC; PAs may co-own with physicians; NPs may not own the medical entity; MSO for non-clinical ownership |
| Telehealth registration | None for MDs; full Tennessee license required; narrow DO telemedicine license; IMLC for physicians; NLC covers RN only |
| In-person exam before prescribing | Not required by statute or Board rule; questionnaire-only prescribing prohibited; federal controlled-substance rules still apply |
| State controlled-substance registration | None for individual prescribers; DEA registration plus mandatory CSMD registration |
| PDMP (CSMD) check | Mandatory for opioids, benzodiazepines and Schedule II amphetamines; recommended for all controlled prescriptions |
| EPCS | Mandatory for Schedule II–V since January 1, 2021 |
| Direct-to-consumer labs | Generally permitted; lab policies govern |
| State tax | No wage income tax; franchise tax 0.25% of net worth ($100 minimum) and excise tax 6.5% of net earnings on entities |
The 12-week Clinic In A Box map applied to Tennessee
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. Tennessee items land in the weeks shown.
- Weeks 1–4, Foundation. Niche and patient avatar; ownership model (physician-owned PC or PLLC, physician-PA co-ownership, or NP-owned MSO with a physician clinical entity) settled with counsel; entity filed and registered agent named; Tennessee license confirmed and any multi-state pathway started; supervising or collaborating physician identified within practical driving distance of the remote site, protocol drafted and the Board of Nursing prescribing notice queued; DEA registration, CSMD registration and NPI; HIPAA framework, BAAs, and an EHR with certified EPCS and Tennessee consent language.
- Weeks 5–8, Operations. Intake and telehealth consent built to Section 63-1-155 and rule 0880-02-.16, including identity verification and history-and-physical documentation; the 20-percent chart-review cycle, controlled-prescription review cycle and 30-day site-visit calendar built into the EHR and the physician’s schedule; the Schedule III formulary and consultation step written into the protocol; lab account opened and Tennessee draw sites mapped; compounding pharmacies vetted by Tennessee license and sterile modifier; cash-pay service menu, subscription option and payment processing live.
- Weeks 9–12, Launch. Patient acquisition across Tennessee’s metros 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 franchise and excise tax calendar, the April annual report and the two-year protocol review.
By week 12 the practice has a compliant Tennessee entity, a filed prescribing notice, 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 Tennessee rules, and how to start a telemedicine hormone clinic for the full sequence. Tennessee 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 Tennessee without a physician?
No. Tennessee requires a supervising physician with a written protocol for any NP who prescribes, with 20 percent chart review every 30 days, closer review of controlled-drug charts and a monthly visit to the NP’s remote site; an NP also may not own the medical professional entity. An NP can build and run the business through an MSO or a nursing-practice entity, but the physician and the review cadence are part of the model. Confirm the structure with the Board of Nursing and counsel.
Does Tennessee require an in-person visit before prescribing testosterone by telemedicine?
Not under state law as of 2026. Section 63-1-155 and Board rule 0880-02-.16 allow a relationship formed by mutual consent through real-time audio-video or store-and-forward with no in-person exam, provided the standard of care is met, identity is verified and a history and physical are documented; prescribing on a questionnaire alone is prohibited. Testosterone is federally Schedule III, so federal telemedicine prescribing rules, extended through December 31, 2026, also apply.
Do I need a Tennessee controlled-substance registration in addition to my DEA number?
Tennessee does not issue a separate controlled-substance registration to individual prescribers, but you must register in the Controlled Substance Monitoring Database within 30 days of receiving a DEA number if you treat Tennessee patients on more than 15 days a year, and a supervised NP and the supervising physician confirm their relationship there. Every controlled substance must be e-prescribed. Confirm with the Board of Pharmacy, which administers the CSMD.
Can I treat Tennessee patients from another state?
Only with full Tennessee authority. Tennessee no longer issues a telemedicine-only license to MDs, so a physician needs a full Tennessee license, which the Interstate Medical Licensure Compact can speed up; DOs should ask their board about its narrow telemedicine license. An APRN needs a Tennessee APRN license, a certificate of fitness and a Tennessee supervising physician who can visit the remote site; a PA needs a Tennessee collaborating physician. The free-clinic volunteer exception in Section 63-1-155 does not cover a cash-pay practice.
Request your free info session
The next step is a free 30-minute info session covering your credential, your Tennessee licensing and supervision situation, your timeline and whether this is the right vehicle. Either way you leave with a clearer next step. Call 844-734-2112 or use the form below.