Kansas Healthcare
Compliance Guide

Kansas presents a generally favorable regulatory environment for healthcare companies, particularly those leveraging telehealth, though it maintains a conservative stance on certain aspects of healthcare delivery and corporate structures. The state has actively embraced telehealth expansion, especially following the COVID-19 pandemic, codifying many temporary flexibilities into permanent law. This has made Kansas an attractive market for telehealth brands in various specialties, including mental health, chronic disease management, and even some aesthetic services. Key regulatory bodies include the Kansas Board of Healing Arts (KBHA) for physicians, physician assistants, and certain other licensed professionals, and the Kansas Board of Nursing for advanced practice registered nurses (APRNs). The state's approach to the Corporate Practice of Medicine (CPOM) is relatively strict, necessitating careful structuring for non-physician-owned entities. Recent legislative actions have focused on solidifying telehealth parity, refining prescribing rules, and addressing scope of practice for mid-level providers. The business climate is generally supportive, but navigating the CPOM and specific licensing requirements is crucial for successful market entry and sustained compliance. Kansas has shown a commitment to increasing access to care, which underpins many of its recent regulatory adjustments, yet it balances this with a strong emphasis on patient safety and professional oversight. Companies must be diligent in understanding the nuances of professional licensure, supervision requirements, and the specific limitations placed on certain types of care delivery, particularly for controlled substances and complex medical services.

Kansas maintains a robust and actively enforced Corporate Practice of Medicine (CPOM) doctrine, primarily rooted in statutory law and reinforced by regulatory interpretation from the Kansas Board of Healing Arts (KBHA). The legal basis for CPOM in Kansas stems from the Professional Corporation Law, K.S.A. 17-2706 et seq., which dictates that professional services, including medical services, must be rendered by licensed professionals. While the statutes do not explicitly prohibit the corporate practice of medicine, the KBHA's long-standing interpretation and enforcement actions effectively prevent unlicensed individuals or entities from employing physicians or controlling the practice of medicine. This means that a general business corporation cannot directly employ physicians to provide medical services or own a medical practice. The primary rationale is to prevent commercial interests from interfering with a physician's independent medical judgment and to ensure that medical decisions are made solely in the best interest of the patient.

Permitted Ownership Structures:

• Professional Corporations (PCs) or Professional Associations (PAs): These entities are specifically designed for licensed professionals to practice their profession. In Kansas, a PC or PA providing medical services must be owned entirely by licensed physicians. K.S.A. 17-2707 specifies that shares of a professional corporation may only be issued to and held by individuals who are licensed to practice the profession for which the corporation is organized. This effectively means non-physicians cannot hold ownership stakes in entities directly providing medical services.
• Physician-Owned Practices: Traditional sole proprietorships, partnerships, or limited liability companies (LLCs) where all owners are licensed physicians are generally compliant.

Restrictions and Impact on Healthcare Businesses:

• Non-Physician Ownership: Non-physicians, including lay entities, cannot own or control medical practices. This directly impacts telehealth companies, medspas, dental practices, and wellness clinics that seek to operate under a single corporate umbrella with non-clinical investors or owners. For instance, a medspa offering medical services (e.g., injectables, laser treatments) must ensure the medical services component is owned and operated by licensed medical professionals.
• Management Services Organizations (MSOs): The MSO model is the most common compliant structure for non-physician investment in Kansas healthcare. An MSO provides administrative, non-clinical services (e.g., billing, marketing, IT, real estate, equipment) to a physician-owned professional entity (PC or PA). The MSO cannot control clinical decisions, employ physicians, or receive a percentage of professional fees that could be construed as fee-splitting. The management services agreement (MSA) between the MSO and the professional entity must be carefully drafted to delineate responsibilities and ensure the professional entity retains full control over clinical matters, including hiring and firing of clinical staff, setting medical protocols, and making all patient care decisions. Compensation to the MSO must be fair market value for the services rendered and not tied to the volume or value of referrals or professional services.
• Fee-Splitting: Kansas prohibits fee-splitting, which is the practice of sharing professional fees with an unlicensed individual or entity in exchange for patient referrals or other services. K.S.A. 65-2837(b)(12) identifies 'fee-splitting' as unprofessional conduct. This reinforces the need for MSO compensation to be based on fair market value for administrative services, not a percentage of professional revenue.

Impact on Specific Entities:

• Telehealth Companies: A telehealth platform seeking to employ physicians directly will face CPOM issues. Instead, they must establish an MSO model, contracting with physician-owned professional entities that employ the licensed providers delivering care via the platform.
• Medspas: If a medspa offers medical services (e.g., Botox, dermal fillers, medical-grade peels, IV therapy), the medical component must be owned and operated by a licensed physician or a physician-owned PC. Non-medical services (e.g., traditional spa services) can be offered by a separate, lay-owned entity, but strict separation of clinical and non-clinical services, as well as clear financial arrangements, are critical.
• Dental and Chiropractic Practices: Similar to medical practices, these must be owned by licensed dentists or chiropractors, respectively, or structured as professional entities owned by such licensees.
• Wellness Clinics: If a wellness clinic provides medical services (e.g., hormone therapy, GLP-1 prescriptions, medical weight loss), it falls under the same CPOM restrictions and must be physician-owned or utilize an MSO model.

Kansas has significantly advanced its telehealth regulations, particularly through the enactment of K.S.A. 40-2,219, which mandates coverage parity for telehealth services and defines key aspects of telehealth practice. The state generally supports the establishment of a provider-patient relationship via telehealth, provided appropriate standards of care are met.

Establishment of Provider-Patient Relationship: Kansas law, specifically K.S.A. 65-28,150, permits the establishment of a valid practitioner-patient relationship through telehealth. This means an in-person visit is not typically required to initiate care, provided the practitioner uses appropriate diagnostic and treatment methods consistent with in-person care. The standard of care for telehealth services is the same as for in-person services. The practitioner must ensure they have sufficient information to make an informed diagnosis and treatment plan.

Permitted Modalities: Kansas law is broad in its acceptance of telehealth modalities, encompassing:

• Synchronous Audio-Visual (Live Video): This is the preferred and most robust modality for establishing a new patient relationship and delivering complex care, as it allows for real-time visual and auditory interaction. K.S.A. 40-2,219 defines 'telehealth' as the use of interactive audio-visual communications.
• Synchronous Audio-Only (Telephone): While K.S.A. 40-2,219 primarily focuses on interactive audio-visual, audio-only encounters are generally permissible for established patients or in situations where audio-visual is not available or appropriate, especially for certain types of follow-up care or mental health services. However, for initial patient encounters or prescribing controlled substances, live video is often explicitly or implicitly required by professional boards.
• Asynchronous (Store-and-Forward): This modality involves the transmission of recorded health information (e.g., images, video, data) to a practitioner for review at a later time. It is permissible, particularly for specialties like dermatology or radiology, but may not be sufficient for establishing a new patient relationship or for prescribing certain medications without supplemental synchronous interaction.
• Remote Patient Monitoring (RPM): The collection of personal health data from a patient in one location and electronic transmission of that data to a practitioner in a different location for use in the patient's care is also permitted.

Telehealth Registration Requirements: Kansas does not have a specific 'telehealth registration' requirement separate from standard professional licensure. Practitioners must be fully licensed in Kansas to provide telehealth services to patients located in Kansas. There are no additional state-level telehealth-specific licenses or registrations required.

Informed Consent Requirements: Informed consent for telehealth services is explicitly required. K.S.A. 65-28,150 mandates that a healthcare provider obtain informed consent from a patient prior to providing telehealth services. This consent must include:

• Identification of the healthcare provider and the patient.
• A description of the telehealth services to be provided.
• A statement that the patient has the right to refuse telehealth services.
• Information on how to access emergency services.
• Information regarding the privacy and security of the telehealth communication.
• Details on how to obtain copies of medical records.
• The patient's right to choose an in-person visit if desired.

Geographic Restrictions: There are no specific geographic restrictions within Kansas for telehealth. A licensed Kansas practitioner can provide telehealth services to any patient located within the state. However, practitioners must be aware of interstate licensing compacts if they wish to provide services to patients located outside of Kansas. Kansas is a member of the Interstate Medical Licensure Compact (IMLC) and the Nurse Licensure Compact (NLC), facilitating multi-state practice for eligible physicians and nurses, respectively.

Kansas maintains stringent regulations regarding the prescribing of controlled substances via telehealth, generally aligning with federal DEA requirements while imposing additional state-specific considerations. The ability to prescribe controlled substances via telehealth largely depends on the establishment of a legitimate practitioner-patient relationship and adherence to the standard of care.

Controlled Substances Prescribed via Telehealth:

• General Rule: Prior to the federal Ryan Haight Online Pharmacy Consumer Protection Act of 2008, prescribing controlled substances without an in-person medical evaluation was largely prohibited. The COVID-19 public health emergency (PHE) waivers temporarily allowed for prescribing of controlled substances via telehealth without an initial in-person exam. As of the anticipated end of the PHE waivers, the DEA has proposed new rules that would generally require an in-person medical evaluation or a referral from a practitioner who has conducted one, before prescribing Schedule II-V controlled substances via telehealth. However, a 30-day supply of Schedule III-V non-narcotic controlled substances may be prescribed following a telehealth evaluation without a prior in-person medical evaluation.
• Kansas Specifics: Kansas law, K.S.A. 65-28,150, states that a practitioner may prescribe, dispense, or administer controlled substances via telehealth if the practitioner has established a valid practitioner-patient relationship and has conducted an appropriate examination. While the statute does not explicitly mandate an 'in-person' exam, the Kansas Board of Healing Arts (KBHA) and the Kansas Board of Pharmacy interpret 'appropriate examination' to necessitate a level of interaction that ensures a thorough assessment, which often implies a live, interactive audio-visual encounter, especially for initial prescriptions of controlled substances. For Schedule II controlled substances, the KBHA generally expects a very high standard of evaluation, often recommending an in-person component or a robust referral process.
• Specific Drug Classes:
  • GLP-1s (e.g., Ozempic, Wegovy): While not controlled substances, these medications require careful medical oversight. Prescribing via telehealth is generally permissible if a comprehensive medical evaluation, including patient history, physical examination (which may be conducted virtually if appropriate), and laboratory testing, is performed. Misuse or inappropriate prescribing can lead to disciplinary action.
  • Testosterone (Controlled Substance, Schedule III): Prescribing testosterone via telehealth is highly scrutinized. An initial in-person evaluation, or a robust telehealth evaluation with comprehensive lab work and a clear medical necessity, is usually expected. Refills may be managed via telehealth for established patients, but ongoing monitoring is critical.
  • Stimulants (e.g., Adderall, Ritalin - Controlled Substance, Schedule II): Prescribing Schedule II stimulants for ADHD via telehealth is among the most challenging areas. Due to their high potential for abuse and diversion, an initial in-person evaluation is strongly recommended, and often required by professional boards, particularly for new patients. Even with federal waivers, state boards maintain the right to enforce higher standards. Ongoing telehealth management for established patients might be possible with strict monitoring protocols.

DEA Requirements: All DEA registrants prescribing controlled substances must comply with federal DEA regulations. This includes maintaining accurate records, adhering to prescribing limits, and ensuring the prescription is for a legitimate medical purpose in the usual course of professional practice. The DEA's proposed rules post-PHE will be critical for telehealth prescribers.

PDMP Checking (Kansas Prescription Monitoring Program - K-TRACS): Kansas law, K.S.A. 65-1683, mandates that prescribers and dispensers check the Kansas Prescription Monitoring Program (K-TRACS) prior to prescribing or dispensing an opioid or benzodiazepine to a patient for the first time, and at least annually thereafter for ongoing treatment. This requirement applies equally to telehealth encounters. Failure to check K-TRACS can result in disciplinary action by the respective licensing board.

Quantity or Refill Limitations: Kansas does not have specific statewide quantity limits for all controlled substances beyond what is medically appropriate and consistent with the standard of care. However, prescribers must exercise professional judgment. For opioids, K.S.A. 65-16,108 places restrictions on initial opioid prescriptions for acute pain, generally limiting them to a 7-day supply, with exceptions for certain conditions. Refills are at the discretion of the prescriber but must be clinically justified and documented.

The scope of practice for mid-level providers in Kansas is defined by statute and further clarified by their respective licensing boards. Understanding these distinctions is critical for compliant healthcare delivery, especially in telehealth and specialized clinics like medspas.

Advanced Practice Registered Nurses (APRNs):

• Full Practice Authority: Kansas does not grant full practice authority to all APRNs. While APRNs (which include Nurse Practitioners, Certified Nurse-Midwives, Clinical Nurse Specialists, and Certified Registered Nurse Anesthetists) have an expanded scope compared to registered nurses, they operate under a collaborative practice agreement or supervision, depending on their specific role and the services provided. K.S.A. 65-1130 broadly defines the practice of an APRN.
• Nurse Practitioners (NPs): NPs in Kansas operate under a written collaborative practice agreement with a physician. This agreement outlines the scope of practice, the types of services the NP can provide, and the methods of collaboration and consultation. The physician does not need to be physically present but must be readily available for consultation. The agreement must be filed with the Kansas Board of Nursing (KBON). NPs can prescribe legend drugs and controlled substances (Schedules II-V) under this agreement, provided it specifies their prescriptive authority and meets all state and federal requirements. K.S.A. 65-1130(e) specifies prescriptive authority for APRNs.

Physician Assistants (PAs):

• Supervision Requirements: PAs in Kansas practice under the supervision of a physician. The supervising physician is responsible for the overall medical care of the PA's patients. While continuous physical presence is not required, the supervising physician must be readily available for consultation and regularly review the PA's practice. The scope of practice for a PA is determined by the supervising physician and must be within the physician's own scope of practice and competence. The KBHA oversees PA licensure and practice. K.S.A. 65-28a01 et seq. governs PA practice.
• Prescriptive Authority: PAs can prescribe legend drugs and controlled substances (Schedules II-V) under the authority delegated by their supervising physician, provided it is within the PA's scope of practice and the physician's license, and in accordance with KBHA regulations.

Other Mid-Level Providers and Delegation:

• Registered Nurses (RNs) and Licensed Practical Nurses (LPNs): These professionals perform nursing tasks within their scope, which generally does not include independent diagnosis, prescribing, or performing medical procedures without delegation or supervision. In medspas, RNs can perform delegated medical procedures (e.g., injectables like Botox) under the direct supervision of a physician or APRN/PA (if the APRN/PA is authorized to delegate and supervise). Direct supervision implies the delegating practitioner is on-site and immediately available.
• Medical Assistants (MAs): MAs in Kansas can perform delegated tasks that do not require independent medical judgment. In medspas or other clinics, MAs can assist with patient intake, prepare rooms, and perform administrative duties. They generally cannot administer injections, perform advanced procedures, or provide medical advice. Any delegated task must be within the scope of practice of the delegating physician, APRN, or PA, and the MA must be trained and competent to perform the task. K.S.A. 65-2801 et seq. and KBHA regulations provide guidance on delegation.

Supervision and Delegation in Telehealth: The principles of supervision and delegation apply equally to telehealth. If an APRN or PA is providing services via telehealth, their collaborative or supervisory agreement must account for this modality. Similarly, if an RN or MA is assisting with telehealth services, the delegating practitioner must ensure appropriate oversight, which may include real-time virtual supervision for certain tasks, depending on the complexity and risk involved.

Navigating Kansas's Corporate Practice of Medicine (CPOM) doctrine necessitates careful business structuring, particularly for entities involving non-clinical ownership or investment. The Professional Corporation (PC) - Management Services Organization (MSO) model is the predominant compliant structure.

PC-MSO Structures:

• When Needed: The PC-MSO model is essential whenever a non-physician individual or entity (e.g., private equity, venture capital, lay investors, or a telehealth technology company) wishes to invest in or manage a healthcare business that provides medical services. This applies broadly to telehealth platforms, medspas, dental practices, chiropractic clinics, and wellness centers offering medical care.
• Professional Corporation (PC): This entity (or Professional Association) must be 100% owned by licensed Kansas physicians (or other licensed professionals for their respective fields, e.g., dentists for a dental PC). The PC employs the clinical staff (physicians, PAs, NPs, RNs performing delegated medical tasks) and holds all licenses, permits, and payer contracts necessary to provide medical services. The PC retains exclusive control over all clinical decisions, medical protocols, hiring/firing of clinical staff, and patient care. Its revenue consists of professional fees for medical services rendered.
• Management Services Organization (MSO): This entity is typically a standard business corporation or LLC that can be owned by non-physicians. The MSO enters into a Management Services Agreement (MSA) with the PC. Under the MSA, the MSO provides all non-clinical, administrative, and management services to the PC. These services may include: billing and collections, marketing, IT support, human resources (for administrative staff), equipment leasing, real estate leasing, supply procurement, and general business management. The MSO cannot interfere with clinical decision-making or control the practice of medicine.

Fee-Splitting Rules: Kansas strictly prohibits fee-splitting, as outlined in K.S.A. 65-2837(b)(12) as unprofessional conduct. This means that the MSO's compensation from the PC cannot be a percentage of the professional fees collected by the PC, nor can it be tied to the volume or value of patient referrals. The MSO's compensation must be structured as a fair market value (FMV) payment for the specific administrative services rendered. Common compliant compensation structures include:

• Fixed monthly management fee.
• Cost-plus model (reimbursement for MSO's costs plus a reasonable margin).
• Per-service unit fee (e.g., per claim processed, per marketing lead).
• Lease payments for equipment and real estate at FMV. Any arrangement that could be perceived as sharing in professional fees or incentivizing referrals is highly risky.

Management Services Agreement (MSA) Requirements: The MSA is the cornerstone of the PC-MSO structure. It must be meticulously drafted to ensure compliance with CPOM and anti-kickback laws. Key provisions include:

• Clear Delineation of Services: Explicitly list all administrative services the MSO provides.
• Clinical Autonomy: Affirm the PC's exclusive control over all clinical matters, including hiring/firing of clinical staff, medical protocols, and patient care decisions.
• Compensation: Detail the MSO's compensation structure, ensuring it is FMV and not tied to professional revenue or referrals.
• Term and Termination: Standard contractual terms.
• Compliance with Laws: Both parties agree to comply with all applicable healthcare laws and regulations.
• No Control over Medical Judgment: Explicitly state that the MSO has no authority over the PC's medical judgment.

Professional Corporation Requirements: As per K.S.A. 17-2706 et seq., a professional corporation in Kansas must:

• Be organized solely for the purpose of rendering a specific professional service.
• Have shareholders who are all licensed in the profession for which the corporation is organized.
• Its corporate name must include words like 'Professional Corporation' or 'P.C.'
• Adhere to specific rules regarding share transfer and corporate governance.

Structuring Ownership for Compliance: For healthcare companies expanding into Kansas, the recommended approach is to establish a Kansas-licensed professional entity (PC) owned by a Kansas-licensed physician(s) to deliver all medical services. A separate, lay-owned MSO can then provide the necessary administrative and business support. This clear separation of clinical and administrative functions, with FMV compensation for the MSO, is the most robust strategy to mitigate CPOM risks in Kansas.

Kansas has seen several significant regulatory developments and legislative activities in the past few years, particularly in the realm of telehealth and professional practice. Staying abreast of these changes is crucial for ongoing compliance.

Telehealth Legislation:

• Permanent Telehealth Parity (2021): House Bill 2066 (K.S.A. 40-2,219) was a landmark piece of legislation that made permanent many of the telehealth flexibilities introduced during the COVID-19 pandemic. It mandates that health insurance carriers provide coverage for telehealth services at a rate not less than the rate for in-person services. This significantly bolstered the financial viability of telehealth in the state. The law also clarified the definition of telehealth and required informed consent.
• Ongoing Refinements: While HB 2066 provided a strong foundation, the Kansas Board of Healing Arts (KBHA) and other professional boards continue to issue guidance and occasional amendments to their regulations to clarify specific aspects of telehealth practice, such as appropriate modalities for certain services or the standard of care for establishing a patient relationship.

Corporate Practice of Medicine (CPOM) Enforcement:

• Continued Vigilance: The KBHA remains vigilant in enforcing CPOM. While no major statutory changes have occurred recently regarding CPOM, the Board continues to scrutinize business arrangements, particularly those involving non-physician ownership or management that could be perceived as interfering with clinical autonomy or involving illegal fee-splitting. Recent enforcement actions, though not widely publicized, often involve investigations into arrangements where MSO fees are tied to a percentage of professional revenue or where lay entities exert undue control over clinical operations.

Interstate Compact Participation:

• Interstate Medical Licensure Compact (IMLC): Kansas became a member of the IMLC, allowing eligible physicians to obtain licenses in multiple compact states more efficiently. This significantly eases the burden for telehealth providers seeking to serve patients across state lines. The KBHA oversees IMLC participation for Kansas-licensed physicians.
• Nurse Licensure Compact (NLC): Kansas is also a member of the NLC, enabling registered nurses and licensed practical nurses to practice in other NLC states without obtaining additional licenses, provided they hold a multi-state license from their home state. This is highly beneficial for APRNs and RNs involved in telehealth.
• Psychology Interjurisdictional Compact (PSYPACT): Kansas is a PSYPACT state, allowing licensed psychologists to practice telepsychology across state lines to other PSYPACT states.

Prescribing Rules and PDMP:

• K-TRACS Enhancements: The Kansas Prescription Monitoring Program (K-TRACS) continues to be a critical tool for combating the opioid crisis. While the mandate for checking K-TRACS for opioids and benzodiazepines has been in place, there are ongoing efforts to integrate K-TRACS more seamlessly into electronic health record systems and to enhance its usability for prescribers and dispensers. No major changes to the specific controlled substance scheduling or prescribing limits have been enacted recently, but federal DEA proposed rules post-PHE are being closely watched.

Pending Legislation (2024-2025 Legislative Session):

• Legislative sessions often bring bills related to scope of practice for various professionals (e.g., optometrists, pharmacists), mental health access, and refinements to existing healthcare laws. While specific bills are subject to change, common themes include further expanding access to mental health services via telehealth, addressing workforce shortages, and potentially refining the definition of 'supervision' or 'collaboration' for mid-level providers. Companies should monitor the Kansas Legislature's website for bill introductions and progress, particularly those related to K.S.A. 65 (Public Health) and K.S.A. 40 (Insurance).

Entering the Kansas healthcare market, especially with telehealth or innovative models, requires a structured approach to ensure compliance from the outset. Here's actionable guidance:

1. Understand and Mitigate CPOM Risk:

• Establish an MSO Model: If your company has non-physician ownership or investment, immediately plan for a Professional Corporation (PC) - Management Services Organization (MSO) structure. The PC must be 100% physician-owned and operate independently regarding clinical decisions.
• Draft a Compliant MSA: Ensure your Management Services Agreement (MSA) clearly delineates administrative services, guarantees the PC's clinical autonomy, and establishes fair market value (FMV) compensation for the MSO, avoiding any percentage-based professional fee arrangements.
• Avoid Fee-Splitting: Scrutinize all financial arrangements to ensure no payments are tied to patient referrals or a percentage of professional service revenue.

2. Secure Proper Licensure:

• Kansas Licensure for All Providers: Every clinician (physician, NP, PA, RN) providing services to patients located in Kansas must hold an active, unrestricted Kansas license. Do not rely on out-of-state licenses, even for telehealth.
• Leverage Compacts: For physicians, utilize the Interstate Medical Licensure Compact (IMLC). For nurses, the Nurse Licensure Compact (NLC). For psychologists, PSYPACT. These compacts streamline multi-state licensure.
• DEA Registration: Ensure all prescribers of controlled substances have an active Kansas DEA registration.

3. Implement Robust Telehealth Protocols:

• Informed Consent: Develop a comprehensive, state-specific informed consent process for telehealth services, ensuring all elements of K.S.A. 65-28,150 are met and documented.
• Standard of Care: Train providers to adhere to the same standard of care for telehealth as for in-person visits. This includes appropriate patient evaluation, diagnosis, and treatment planning.
• Modality Selection: Use synchronous audio-visual for initial patient encounters, especially when prescribing new medications or controlled substances, unless explicitly permitted otherwise by board guidance.

4. Strict Adherence to Prescribing Rules:

• K-TRACS Compliance: Mandate and document K-TRACS checks for all opioid and benzodiazepine prescriptions as required by K.S.A. 65-1683.
• Controlled Substance Caution: Exercise extreme caution with telehealth prescribing of Schedule II controlled substances. An initial in-person exam or referral from a practitioner who has conducted one is generally the safest approach, especially post-PHE waivers. Document medical necessity thoroughly.
• Specific Drug Classes: For GLP-1s, testosterone, and stimulants, ensure comprehensive patient evaluation, appropriate lab work, and ongoing monitoring, documenting all clinical decisions.

5. Respect Scope of Practice and Supervision:

• APRNs: Ensure all Nurse Practitioners operate under a current, filed collaborative practice agreement with a Kansas-licensed physician. Review the agreement regularly.
• PAs: Verify that all Physician Assistants have a supervising physician who is readily available for consultation and regularly reviews their practice.
• Delegation: For RNs and MAs performing delegated tasks (e.g., in medspas), ensure the delegating practitioner is appropriately licensed, on-site for direct supervision where required, and that the delegate is trained and competent.

Common Pitfalls to Avoid:

• Ignoring CPOM: Assuming a national model is compliant in Kansas without local legal counsel review.
• Lack of Kansas Licensure: Providing services to Kansas patients without a Kansas license.
• Inadequate Documentation: Especially for telehealth encounters and controlled substance prescriptions.
• Improper MSO Compensation: Structuring MSO fees as a percentage of professional revenue.
• Insufficient Supervision: For NPs, PAs, and delegated tasks, failing to meet Kansas's specific supervision/collaboration requirements.

Timeline Expectations:

• Provider Licensing: 2-6 months (can be faster with compacts).
• Entity Formation: 2-4 weeks (for PC and MSO).
• Payer Enrollment: 3-6 months (commercial), 6-12 months (Medicaid).
• Overall Setup: Plan for 6-12 months for full operational readiness, including legal review, entity formation, licensing, and credentialing.