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Telemedicine-Only State Medical Licenses

I learned about telemedicine-only state medical licenses after reading Scott Rattigan’s book The Practice of Telemedicine. He refers to these as Special Purpose Telemedicine Licenses or Telehealth Registrations.

If you have a medical practice and your patient travels to another state, you can often see them and perhaps even prescribe an antibiotic or refill a medication at an out-of-state pharmacy. But only for a few visits.

Up-to-date state-by-state list of telemedicine policies.

Up-to-date list of states with permanent interstate telemedicine rules.

Telemedicine State License

These telemedicine-only state licenses allow you to only see patients virtually as a physician. This means you can obtain such a medical license while you reside and are licensed in your home state and market to and conduct medical appointments in such destination states.

I’m licensed in CA, so with a reciprocal telemedicine-only state license, I can practice in other states, such as:

I won’t offer a full list here because this information will be outdated quickly. The best way would be to look up each state and determine if they offer a telemedicine-only license.

As of this writing, 16 21 states offer such a limited license. There is a state-by-state comparison in this pdf document by the FSMB.

Application Requirements

The usual culprits are required for licensure, which will vary from state to state:

  • application fee
  • current, unrestricted state licensure
  • application
  • NPDB report
  • notary
  • renewal every 1-3 years
  • background check
  • malpractice coverage
  • FCVS application
  • state license verification

The requirements vary from state to state. You obviously must be licensed in your home state, and they must accept that state as a regulating state.

Based on the fact that another state already approved you to be a licensed physician, they will extend a reciprocal telemedicine license. Imagine that; what an idea!

There is an application fee, of course.

There are restrictions based on whether you ever had a medical board investigation (guilty!). Some won’t accept you if you ever had one, while others have a 5-year statute.

You may have to prove that you have malpractice coverage for that state if required.

You may have to designate a registered agent for most of these limited telemedicine licensures.

Downsides to Multi-State Licensure

There are endless things I could list as downsides to having multistate licensure. Even a telemedicine-only state license puts you at risk because you will be held to the standards of that state with which you may not be as familiar.

There are fees to pay, applications to fill out, renewals to consider, and DEA applications if you plan on prescribing in another state.

This doesn’t mean that you shouldn’t get multi-state licensed. Instead, it’s worthwhile to have an attorney like the Functional Lawyer who can help you oversee the entire process.

I have a growing list of vetted attorneys for physicians on this page.

California State Medical License

I have a CA license, and our population here is ~40 million. I can’t imagine needing a larger marketplace to grow my practice.

However, marketing my virtual practice in CA will likely be more expensive because competition is more fierce.

I wouldn’t consider obtaining another state medical license until I’ve exhausted my marketing in CA – assuming I’m concerned mostly about my virtual practice.

Those of you working for telemedicine companies may need more licenses to get enough gigs. There are some arguments to be made for that kind of work and some arguments against it.

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