District of Columbia Healthcare & Telehealth Compliance Guide
The District of Columbia does not have a single freestanding Corporate Practice of Medicine statute, but its Professional Corporation Act functions as one of the strictest ownership regimes in the country. DC Code § 29-508 requires that every shareholder, director, and specified officer (board chair, president, vice-president, treasurer, secretary) of a medical professional corporation be an individual licensed to render that professional service — meaning a medical PC must be 100% physician-owned and physician-governed. DC Code § 29-511 further limits share transfers to licensed individuals or the corporation itself, closing off any path to non-physician equity. Regulators and courts also apply a 'control test' (interference with clinical judgment, deriving profit from medical services, commercialization of medicine) consistent with strict CPOM jurisdictions like California and New York. A carefully structured PC-MSO arrangement — a physician-owned clinical PC/PLLC paired with a separately owned management services organization limited to non-clinical functions — remains the standard path for telehealth and medspa operators, but the MSO cannot hold equity in, or exert clinical control over, the licensed entity.
- Corporate Practice of Medicine (CPOM): Strict
- Telehealth prescribing permitted: Yes
- In-person exam required first: No
- Audio-only visits allowed: Yes
- Nurse practitioner authority: Full
- Collaborative practice agreement required: No
- Good Faith Exam required: Yes
Frequently asked questions
How does DC's Corporate Practice of Medicine rule affect my healthcare business?
The District of Columbia doesn't have a single CPOM statute, but its Professional Corporation Act (DC Code § 29-508) requires 100% physician ownership, and physician directors and officers, for any medical professional corporation — one of the strictest ownership regimes in the country. Non-physician investors cannot hold equity in the clinical entity. You'll need a properly structured PC-MSO arrangement, with the MSO limited to non-clinical services, to operate compliantly. TrueEval can guide you through the entity formation and management services agreements required.
Do I need a medical director for my medspa or IV therapy clinic in DC?
Yes — because DC requires the clinical entity behind a medspa, IV therapy clinic, or similar establishment to be 100% physician-owned, you need a DC-licensed physician serving as medical director to develop protocols, provide clinical oversight, and ensure regulatory compliance. TrueEval places board-certified medical directors licensed in DC who understand both telehealth and in-person practice requirements.
Can nurse practitioners practice independently in the District of Columbia?
Yes. Following the 2023–2024 Health Occupations Revision General Amendment Act, DC grants full practice authority to nurse practitioners, allowing them to evaluate, diagnose, prescribe, and manage treatment without a mandatory collaborating physician. TrueEval helps you navigate DC's specific NP scope-of-practice rules for both telehealth and brick-and-mortar operations.
Can I prescribe medications via telehealth in the District of Columbia?
Yes, telehealth prescribing is permitted in DC. No prior in-person visit is required, provided the encounter includes an appropriate patient evaluation meeting DC Board of Medicine standards — a questionnaire alone isn't sufficient. Real-time audio or audio-video is expected for new patient relationships. TrueEval ensures your prescribing protocols meet DC's requirements.
What compliance requirements apply to cash-pay healthcare businesses in the District of Columbia?
Cash-pay healthcare operations in DC — including telehealth, medspas, IV therapy, and wellness clinics — must still comply with DC's health occupation laws, its strict professional-corporation ownership rules, prescribing regulations, and scope-of-practice requirements. The main difference is you won't deal with insurance billing compliance, but you must still maintain a compliant PC-MSO structure, physician oversight, and clinical documentation. TrueEval specializes in cash-pay compliance frameworks for DC.