Yes: a nurse practitioner, physician assistant or physician can open a cash-pay telemedicine hormone practice in Utah, and for nurse practitioners it is one of the cleanest states in the country to do it in. APRNs hold full practice authority with Schedule II through V prescribing and no collaborating physician; PAs practice under a collaboration model that phases out the written agreement after 8,500 hours; Utah has no strict corporate-practice-of-medicine doctrine; and the telehealth statute lets a provider-patient relationship begin during a video visit. The gating items are a Utah license for anyone treating Utah patients, a separate Utah controlled-substance license from DOPL on top of the DEA registration, electronic prescribing of every controlled drug, and an entity that fits Utah’s professional-entity rules. This is a 2026 planning summary, not legal advice; confirm every point with the Utah Division of Professional Licensing (DOPL) and counsel, because rules change.
Utah practice authority: who can run and own a telemedicine hormone practice
Nurse practitioners in Utah
Utah is a full practice authority state. An APRN licensed by DOPL under the Nurse Practice Act (Utah Code Title 58, Chapter 31b) diagnoses, treats and prescribes under the nursing license alone: no supervising or collaborating physician, no delegation agreement and no transition-to-practice hours. The last physician tether was removed in 2023, when S.B. 36 (effective May 3, 2023) struck the mentorship and consultation-and-referral conditions that had applied to Schedule II prescribing by APRNs in independent solo practice during their first year or first 2,000 hours. Section 58-31b-803 now simply states that a licensed APRN may prescribe or administer a Schedule II controlled substance, with a carve-out only for nurse anesthetists. Testosterone, a Schedule III drug, sits inside that scope.
What the APRN needs is a Utah APRN license with prescriptive authority, a Utah controlled-substance license from DOPL (a separate application with its own fee), a DEA registration tied to a Utah practice address, and the controlled-substance prescribing continuing education DOPL requires each renewal cycle. Utah has enacted the APRN Compact, but it has not yet reached the number of states needed to activate, so an out-of-state NP applies for a Utah APRN license by endorsement; the Nurse Licensure Compact covers the RN license only. Confirm current requirements in Utah Administrative Code R156-31b.
Physician assistants in Utah
Utah replaced PA supervision with collaboration in 2021 (Utah Code Title 58, Chapter 70a), and the 2026 General Session loosened it further. Under Section 58-70a-307 as amended effective May 6, 2026, a PA with fewer than 8,500 hours of post-graduate clinical practice works under written practice-level policies that describe how collaboration occurs and how competency is evaluated. For the first 4,000 hours the PA collaborates with a physician. Between 4,000 and 8,500 hours the PA signs a written collaborative agreement with a physician, or with a PA who has more than 8,500 hours in the same specialty; the agreement is kept at the practice location and produced on request, not filed with DOPL. Past 8,500 hours no agreement is required. A PA moving into a specialty with fewer than 4,000 hours of experience collaborates for 4,000 hours with a physician trained in it, which matters if hormone therapy is new ground. The statute sets no physician-to-PA ratio.
PAs prescribe within their scope and, for controlled substances, need the same Utah controlled-substance license and DEA registration as any other prescriber. Older DOPL forms still show the pre-2026 10,000-hour threshold, so read the current statute and R156-70a with counsel rather than the form.
Physicians and the corporate practice of medicine
Utah is generally described as a state without a strict corporate-practice-of-medicine doctrine. The Medical Practice Act (Section 58-67-802) lists the forms in which a physician may practice, including sole proprietorship, employment, partnership, professional corporation, limited liability company and business corporation, while requiring that only a licensed physician actually conduct the practice of medicine in any of them. The practical limit comes from the professional-entity statutes: a Utah professional corporation (Title 16, Chapter 11) and a professional limited liability company (Title 48, Chapter 3a) restrict owners to individuals licensed to render the same professional service. Non-clinician partners and investors therefore sit in a separate management services organization under a fair-market-value agreement, which is the common Utah structure. A physician starting a cash-pay hormone clinic typically forms a PLLC or PC and owns it outright.
So who may own the practice?
A physician may own it outright. An NP may own it outright and practice without any physician. A PA may own it with the collaboration arrangement the hour thresholds require. Whether an NP and a physician may co-own a single professional entity turns on how the professional-services definition treats different licenses, so have a Utah health-care attorney confirm mixed ownership before filing; a non-clinician spouse, marketer or investor belongs in the MSO.
Utah telehealth rules for a remote hormone practice
The Telehealth Act. Utah Code Section 26B-4-704 governs telemedicine for every DOPL-licensed provider. The provider acts within the scope of the Utah license and is held to the same standards of practice as in a traditional setting. If no provider-patient relationship exists, the provider establishes one during the encounter in the manner DOPL sets by rule, including disclosing licensure and credentials. Before treating or prescribing, the provider establishes a diagnosis and identifies contraindications after obtaining and documenting the patient’s clinical history and current symptoms. A provider may not diagnose, treat or prescribe based solely on an online questionnaire, an email or a patient-generated medical history, which rules out asynchronous intake-form prescribing but not a synchronous video visit. The provider must be available for follow-up care, know the emergency resources near the patient and, where the patient has a designated primary provider, offer to send that provider a report within two weeks unless the patient declines. No statute requires an in-person examination before prescribing; the standard of care and, for controlled substances, federal law govern. Utah’s former Online Prescribing Act was repealed in 2023.
Licensure and patient location. Utah treats care as delivered where the patient is. A patient physically in Utah must be treated by someone holding a Utah license, or the temporary telemedicine license under Section 58-1-302.1, which DOPL issues to an out-of-state licensee in good standing who has filed a Utah endorsement application that cannot be processed within 15 days; it covers only services the home-state license allows and only while the patient is in Utah. There is no standalone telehealth registration for out-of-state practitioners. Physicians licensed elsewhere can use the Interstate Medical Licensure Compact, of which Utah is a member; APRNs and PAs apply to DOPL by endorsement.
Consent and the DOPL telehealth rule. Utah Administrative Code R156-1-602 fills in the statute: before each encounter the provider verifies the patient’s identity and originating site and, where feasible, lets the patient choose the provider; before the first encounter the provider obtains informed consent covering any telehealth-specific fees, who health information may be disclosed to and the patient’s rights regarding it. Build this into intake as a signed telehealth consent.
Controlled substances and registrations. Utah requires every person who prescribes, dispenses or administers a Schedule I through V controlled substance in Utah to hold a Utah controlled-substance license from DOPL (Section 58-37-105 as renumbered effective July 1, 2026, formerly 58-37-6), renewed on a two-year cycle. DOPL rule R156-37-305 then expects the licensee to obtain a DEA registration within 120 days of the state license, and the state license is suspended automatically if the DEA registration lapses. Utah also mandates electronic prescribing of controlled substances: Section 58-37-302 (formerly 58-37-22) has required e-prescribing of every controlled-substance prescription since January 1, 2022, with limited exemptions, and enforcement began January 1, 2024, so an EHR with certified EPCS is a baseline. Controlled-substance prescribers also complete DOPL-approved prescribing education each renewal (Section 58-37-303).
The Controlled Substance Database. Under Section 58-37f-304 a prescriber must check the Utah Controlled Substance Database before the first prescription for a Schedule II or III opioid and periodically thereafter when prescribing repeatedly. Testosterone is not an opioid, so the mandatory check does not attach as commonly read, but querying the database for every controlled prescription is sound practice and is what a reviewer expects to see. Federal telemedicine rules for controlled substances have been extended and revised repeatedly, so confirm the current federal position on in-person evaluation before the first testosterone prescription.
See the full 12-week program →
Entity options, registered agent and Utah taxes
Clinicians choose between a professional limited liability company and a professional corporation, both filed with the Utah Division of Corporations and Commercial Code. A PLLC renders professional services only through licensed members and employees, so the ownership question comes before the filing. Any MSO is an ordinary LLC. Every Utah entity names a registered agent with a physical Utah street address and files a short annual renewal with the Division of Corporations for a modest fee, due in the anniversary month; missing it leads to administrative dissolution.
Utah taxes income at a single flat rate. For 2026 the individual rate is 4.45 percent under S.B. 60, down from 4.5 percent in 2025, and the corporate franchise tax sits at the same rate with a $100 minimum; a PLLC taxed as a partnership or S corporation passes income through to the owners and pays no entity-level franchise tax. Treat these as typical figures to confirm with a Utah CPA, because the rate has moved almost every year.
Labs and pharmacy in Utah
Utah is commonly treated as a permissive state for consumer-initiated laboratory testing, and the national laboratories list consumer panels for Utah ZIP codes. An older professional-society survey placed Utah among states with some limits on direct-access testing, and Utah facility rules tie lab services in licensed facilities to an order from someone licensed to prescribe, so confirm the policy with the laboratory you use. In a cash-pay hormone model the question rarely matters, because the clinic orders the panel under its own lab 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 nonresident licensing. A compounding pharmacy outside Utah that ships to Utah patients must hold a Utah Class D pharmacy license from DOPL (Section 58-17b-306), the nonresident class. A Class D applicant that compounds submits a compounding inspection report from the past two years (NABP Verified Pharmacy Program or its home-state board) along with a pharmacy care protocol under R156-17b-616, and must follow USP 795 and 797; Utah’s own compounding standards in R156-17b-614e were updated effective December 31, 2025. Ask any pharmacy for its Utah Class D license number and whether it is licensed for sterile compounding before routing the first injectable testosterone prescription, and keep a Utah-based 503A compounder as a backup.
Utah at a glance
| Item | Utah (confirm with DOPL, the board or counsel) |
|---|---|
| NP practice authority | Full; no collaborating physician; Schedule II–V with a Utah controlled-substance license and DEA; Schedule II conditions repealed by S.B. 36 (2023) |
| PA model | Collaboration under 58-70a-307 (amended May 6, 2026): physician collaboration for the first 4,000 hours; written collaborative agreement from 4,000 to 8,500 hours, kept on file; none after 8,500 hours; no ratio |
| Corporate practice of medicine | No strict doctrine; professional entities limited to same-profession licensees; MSO for non-clinicians |
| Telehealth registration | None; Utah license required; temporary telemedicine license under 58-1-302.1 while an endorsement application is pending; IMLC for physicians; NLC covers RN only; APRN Compact enacted but not active |
| In-person exam before prescribing | Not required by statute; no prescribing on an online questionnaire, email or patient-generated history alone; federal controlled-substance rules still apply |
| State controlled-substance registration | Required: Utah controlled-substance license from DOPL in addition to DEA; two-year renewal; EPCS mandatory since January 1, 2022 |
| PDMP (Controlled Substance Database) | Mandatory check before the first Schedule II or III opioid prescription and periodically after; recommended for all controlled prescriptions |
| Direct-to-consumer labs | Generally available; lab policies govern; clinic-ordered model sidesteps the question |
| State tax | Flat 4.45 percent individual and corporate rate for 2026; pass-through entities pay no entity-level franchise tax; modest annual entity renewal |
The 12-week Clinic In A Box map applied to Utah
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. MultiGen Wellness Institute is itself Utah-based, with its business address in Hildale, so the Utah pathway below is the one the Institute’s own clinics operate under. The Utah items land in the weeks shown.
- Weeks 1–4, Foundation. Niche and patient avatar; ownership model (NP-owned PLLC, physician-owned PLLC or PC, PA ownership with collaboration, or MSO) settled with counsel; entity filed and registered agent named; Utah license confirmed and any multi-state pathway started; for PAs, the practice-level policies and, where the hours require it, the collaborative agreement drafted; Utah controlled-substance license filed and the DEA registration queued within the 120-day window; NPI; HIPAA framework, BAAs, and an EHR with certified EPCS, Controlled Substance Database integration and Utah telehealth consent language.
- Weeks 5–8, Operations. Intake built to Section 26B-4-704 and R156-1-602: identity and originating-site verification, credential disclosure, informed consent before the first visit, documented history and diagnosis before any prescription, and the two-week report to the patient’s designated provider; a synchronous-video prescribing workflow that never relies on a questionnaire alone; lab account opened and draw sites mapped from St. George to Logan; compounding pharmacies vetted by Utah Class D license and sterile-compounding status; cash-pay service menu, subscription option and payment processing live.
- Weeks 9–12, Launch. Patient acquisition for the Wasatch Front, Washington County and rural Utah (Google Business where eligible, referrals, organic search); soft launch and first patients seen; revenue and retention tracking; a 90-day roadmap including the entity renewal month, the two-year DOPL renewal cycle and, for PAs, the hour log that phases out the collaborative agreement.
By week 12 the practice has a compliant Utah entity, 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 Utah rules, and how to start a telemedicine hormone clinic for the full sequence. Utah 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 Utah without a physician?
Yes. Utah APRNs practice and prescribe independently, including Schedule II through V controlled substances such as testosterone, with no collaborating or supervising physician and no transition period; the former mentorship and consultation-and-referral conditions on Schedule II prescribing were repealed in 2023. The NP needs a Utah APRN license with prescriptive authority, a Utah controlled-substance license from DOPL, a DEA registration and a professional entity owned by licensed professionals. Confirm current scope rules with DOPL and the Utah Board of Nursing.
Does Utah require an in-person visit before prescribing testosterone by telemedicine?
Utah statute does not. Section 26B-4-704 allows the provider-patient relationship to be established during a telehealth encounter and applies the same standard of care as in-person practice, provided the provider documents the history, establishes a diagnosis and does not prescribe on an online questionnaire, email or patient-generated history alone. 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 before prescribing.
Do I need a Utah controlled-substance license in addition to my DEA number?
Yes. Utah requires anyone who prescribes, dispenses or administers a controlled substance in the state to hold a controlled-substance license from DOPL, renewed on a two-year cycle, in addition to a DEA registration tied to a Utah practice address; DOPL rule expects the DEA registration within 120 days of the state license. Every controlled-substance prescription must also be sent electronically. Confirm the current application and fee with DOPL.
Can I treat Utah patients from another state?
Only with a Utah license, or the temporary telemedicine license DOPL issues to an out-of-state licensee in good standing whose Utah endorsement application cannot be processed within 15 days. Care is treated as delivered where the patient is, and Utah has no general telehealth registration for out-of-state providers as of 2026. Physicians can use the Interstate Medical Licensure Compact; APRNs and PAs apply to DOPL by endorsement, since the APRN Compact is not yet active and the Nurse Licensure Compact covers only the RN license.
Request your free info session
The next step is a free 30-minute info session covering your credential, your Utah licensing and entity 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.