Yes: a nurse practitioner, physician assistant or physician can open a cash-pay telemedicine hormone practice in Washington, and for nurse practitioners it is one of the most direct states in the country. ARNPs hold full practice authority with Schedule II through V prescribing and no collaborating physician; PAs moved to collaboration agreements on January 1, 2025; and the Uniform Telehealth Act lets a practitioner-patient relationship begin by telehealth. The gating items are a Washington license for anyone treating Washington patients, a telemedicine training for non-physicians, DEA registration with electronic prescribing and PMP registration, and an entity that respects Washington’s corporate-practice-of-medicine doctrine. This is a 2026 planning summary, not legal advice; confirm every point with the Washington State Board of Nursing, the Washington Medical Commission and counsel, because rules change.
Washington practice authority: who can run and own a telemedicine hormone practice
Nurse practitioners in Washington
Washington is a full practice authority state. An ARNP licensed by the Washington State Board of Nursing (formerly the Nursing Care Quality Assurance Commission) diagnoses, treats and prescribes under the nursing license alone: no supervising or collaborating physician, no joint practice arrangement and no transition-to-practice hours. The joint-practice requirement for controlled substances was repealed in 2005, and RCW 18.79.240 and 18.79.250 now allow an ARNP with prescriptive authority to prescribe legend drugs and Schedule II through V controlled substances within the board-defined scope. Testosterone, a Schedule III drug, sits squarely inside that scope.
What the ARNP needs is a Washington ARNP license with the prescriptive-authority designation, a DEA registration tied to a Washington address, and the telemedicine training discussed below. The credential is renamed “advanced practice registered nurse” on June 30, 2027 without a change in scope; confirm current rules in chapter 246-840 WAC.
Physician assistants in Washington
ESHB 2041 (chapter 62, Laws of 2024) rewrote PA practice effective January 1, 2025. The old practice agreement became a collaboration agreement: a written document signed by the PA and one or more physicians, or the PA’s employer, covering duties, communication and decision-making, backup coverage, the PA’s attestation of postgraduate hours, and termination. It is not filed with the Washington Medical Commission; it is kept at the practice location and produced on request.
The experience threshold matters for a startup. A PA with fewer than 4,000 hours of postgraduate clinical practice must be supervised by a participating physician; with 4,000 or more hours, including 2,000 supervised in the chosen specialty, the PA may practice in collaboration, and the Commission describes no fixed physician-to-PA ratio under that model. PA prescribing is commonly read to include Schedule II through V within the agreement; verify the current chapter 246-918 WAC text, amended December 15, 2024, before building the prescribing workflow.
Physicians and the corporate practice of medicine
Washington does recognize the corporate practice of medicine doctrine, although the state is often described loosely as permissive. In Morelli v. Ehsan (1988) the Washington Supreme Court held that an unlicensed person may not own, maintain or operate a business that practices medicine, and a 1997 attempt to abrogate the doctrine was vetoed. Only licensed professionals may own the clinical entity; non-clinicians participate through a management services organization under a fair-market-value agreement that leaves clinical judgment with the licensees.
Where Washington is genuinely flexible is in who counts as a permitted owner. RCW 18.100.050(5)(a) lets professionals licensed under roughly twenty listed chapters, including physicians, osteopathic physicians, ARNPs, physician assistants, chiropractors and naturopaths, own one professional service corporation together, and a 2020 Attorney General opinion applies the same rule to PLLCs. A physician and a nurse practitioner may therefore co-own the practice, which is unusual nationally.
So who may own the practice?
A physician may own it outright. An ARNP may own it outright and practice without any physician. A PA may own it with a collaboration agreement in place. Mixed ownership among the listed professions is permitted; ownership by a non-clinician spouse, investor or marketer is not, and belongs in a separate MSO. Have a Washington health-care attorney confirm the model before filing.
Washington telehealth rules for a remote hormone practice
The Uniform Telehealth Act. Effective June 6, 2024, chapter 18.134 RCW governs telehealth for every listed profession. A practitioner-patient relationship may be established through telehealth, though not through email, text or fax alone. The practice standard is the same as in person, and disciplining authorities may not adopt a different standard merely because care is remote. No statute requires an in-person examination before prescribing; the standard of care and, for controlled substances, federal law govern. The Medical Commission’s telemedicine guideline asks for especially careful consideration before prescribing DEA-controlled drugs, so document the indication, labs and risk discussion for every testosterone prescription.
Licensure and patient location. Under RCW 18.134.060 the service occurs where the patient is, so Washington law applies to any Washington patient. An out-of-state practitioner may treat a Washington patient only with a Washington license or authorization through a compact Washington belongs to; the exceptions are consultation with a Washington practitioner who keeps responsibility, specialty assessment without treatment, and short-term continuity care. A registration pathway for out-of-state providers was stripped from the 2023 bill for study, and as of this writing none exists. Physicians licensed elsewhere can use the Interstate Medical Licensure Compact, which Washington joined in 2017. Washington joined the Nurse Licensure Compact in 2023 and issues multistate RN licenses, but that covers the RN license only; an ARNP applies for a Washington ARNP license directly.
Telemedicine training. RCW 43.70.495 requires every health care professional who provides clinical services through telemedicine, other than MDs and DOs, to complete a training covering state and federal law, liability and informed consent, then sign and retain an attestation. The Board of Nursing reads it as due within one year of initial licensure; the statute states no repeat interval, so it is commonly treated as one-time. A free course is available through the state collaborative.
Consent, billing and data. Washington has no telehealth-specific informed-consent statute covering every profession, so general consent law and the Commission guideline govern; a written telehealth consent in intake is the conservative practice. RCW 18.134.070 bars directly billing a patient for certain non-telemedicine telehealth services without prior consent, so obtain written consent to direct billing before the first visit. The My Health My Data Act (chapter 19.373 RCW) regulates consumer health data outside HIPAA, which reaches website analytics, ad pixels and lead forms; review it with counsel before marketing.
Controlled substances and registrations. Washington has no separate state controlled-substance registration for prescribers: the Washington license plus a DEA registration tied to a Washington address is the set. Electronic prescribing of Schedule II through V drugs has been mandatory under RCW 69.50.312 since January 1, 2021, with limited exemptions, so an EHR with certified EPCS is a baseline. Every Schedule II through V prescriber must register with the Prescription Monitoring Program under chapter 70.225 RCW and the profession rules (WAC 246-919-985 for physicians, WAC 246-840-4990 for ARNPs, with a parallel PA rule). Mandatory queries attach to opioids and the drugs named in the co-prescribing rules; testosterone is not on that list as commonly read, but querying every controlled prescription is sound practice and may be required when the EHR integrates PMP access. Federal telemedicine rules for controlled substances change often, so confirm the current federal position before the first prescription.
See the full 12-week program →
Entity options, registered agent and Washington taxes
Clinicians choose between a professional limited liability company under RCW 25.15.046 and a professional service corporation under chapter 18.100 RCW, both filed with the Secretary of State. A PLLC follows the professional-corporation rules, so membership is limited to licensed professionals, and members of a PLLC without at least $1 million in professional liability coverage can be personally exposed to that extent. Any MSO is an ordinary LLC. Every entity needs a registered agent with a physical Washington street address, a state business license and UBI number, and an annual report to the Secretary of State.
Washington has no personal or corporate income tax. The state cost is the business and occupation tax, a gross-receipts tax with no deduction for expenses. Medical services typically fall under Service and Other Activities: 1.5 percent for businesses under $1 million in prior-year Washington receipts, 1.75 percent from $1 million to $5 million, and 2.1 percent above $5 million since October 1, 2025. A small-business credit shields the smallest practices, and some cities, including Seattle, levy their own B&O tax. A 7 percent excise on large long-term capital gains matters if the practice is ever sold. Treat these as typical figures to confirm with a Washington CPA.
Labs and pharmacy in Washington
Washington is generally listed among the states that permit direct-access laboratory testing, and the national laboratories offer consumer-initiated panels there; individual labs set their own policies, 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 visits a nearby draw site and results flow into the EHR. A clinic that performs any testing itself needs a medical test site license under chapter 70.42 RCW in addition to CLIA.
The pharmacy detail that trips new practices up is nonresident licensing. A compounding pharmacy outside Washington that ships to Washington patients must hold a nonresident pharmacy license from the Pharmacy Quality Assurance Commission under RCW 18.64.360, supported since 2019 by a recent inspection report from an approved program, and compounded products must meet USP standards under RCW 18.64.270. Ask any pharmacy for its Washington nonresident license number before routing the first prescription, and keep a Washington-licensed 503A compounder as a backup.
Washington at a glance
| Item | Washington (confirm with the board or counsel) |
|---|---|
| NP practice authority | Full; no collaborating physician; Schedule II–V with DEA; credential renames to APRN June 30, 2027 |
| PA model | Collaboration agreement under ESHB 2041 (effective January 1, 2025); supervision until 4,000 postgraduate hours; not filed with the Commission; no fixed ratio |
| Corporate practice of medicine | Recognized (Morelli v. Ehsan); licensed professionals only; physicians, ARNPs and PAs may co-own one entity under RCW 18.100.050(5)(a); MSO for non-clinicians |
| Telehealth registration | None; Washington license required; IMLC for physicians; NLC covers RN only; telemedicine training for non-physicians (RCW 43.70.495) |
| In-person exam before prescribing | Not required by statute; relationship may begin by telehealth; federal controlled-substance rules still apply |
| State controlled-substance registration | None; DEA registration only; EPCS mandatory since January 1, 2021 |
| PDMP | Registration required for all Schedule II–V prescribers; mandatory queries for opioids and co-prescribed drugs; recommended for all controlled prescriptions |
| Direct-to-consumer labs | Generally permitted; lab policies govern |
| State tax | No income tax; B&O gross-receipts tax 1.5–2.1 percent on services by revenue tier; 7 percent capital gains excise above threshold |
The 12-week Clinic In A Box map applied to Washington
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 Washington items land in the weeks shown.
- Weeks 1–4, Foundation. Niche and patient avatar; ownership model (ARNP-owned PLLC, physician-owned entity, mixed clinician ownership or MSO) settled with counsel; entity filed, registered agent named, business license issued; Washington license confirmed and any multi-state pathway started; for PAs, the collaboration agreement drafted; telemedicine training completed; DEA, PMP and NPI registrations; HIPAA framework, BAAs, an EHR with EPCS and PMP integration, and a My Health My Data review of the website.
- Weeks 5–8, Operations. Intake built to chapter 18.134 RCW with telehealth consent and consent to direct billing; prescribing workflow with the controlled-substance documentation the Commission guideline expects; lab account opened and draw sites mapped from Seattle and Spokane to the Tri-Cities; compounding pharmacies vetted by Washington nonresident license; cash-pay service menu, subscription option and payment processing live.
- Weeks 9–12, Launch. Patient acquisition for Washington 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 B&O filing calendar and the annual report.
By week 12 the practice has a compliant Washington 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 Washington rules, and how to start a telemedicine hormone clinic for the full sequence. Washington 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 Washington without a physician?
Yes. Washington ARNPs 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 ARNP needs a Washington ARNP license with prescriptive authority, DEA and PMP registration, the RCW 43.70.495 telemedicine training and an entity owned by licensed professionals. Confirm current scope rules with the Washington State Board of Nursing.
Does Washington require an in-person visit before prescribing testosterone by telemedicine?
Washington statute does not. The Uniform Telehealth Act allows the practitioner-patient relationship to be established by telehealth and applies the same standard of care as in-person practice. 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 the Medical Commission’s telemedicine guideline before prescribing.
Can a physician assistant own a telemedicine practice in Washington?
Generally yes. Physician assistants are among the professions that may own a professional service corporation or PLLC under RCW 18.100.050(5)(a), and since January 1, 2025 the practice relationship is a collaboration agreement rather than a delegation. A PA with fewer than 4,000 postgraduate hours must be supervised by a participating physician, and every PA needs a signed agreement kept at the practice location. Confirm the structure with the Washington Medical Commission and counsel.
Can I treat Washington patients from another state?
Only with a Washington license or authorization through a compact Washington belongs to. The Uniform Telehealth Act treats care as occurring where the patient is, and the exceptions for out-of-state practitioners are limited to consultation, specialty assessment without treatment and short-term continuity care. Washington has no telehealth registration for out-of-state providers as of 2026. Physicians can use the Interstate Medical Licensure Compact; ARNPs apply to the Washington State Board of Nursing directly.
Request your free info session
The next step is a free 30-minute info session covering your credential, your Washington 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.