Virginia Healthcare & Telehealth Compliance Guide
Virginia does not have a formal Corporate Practice of Medicine (CPOM) doctrine. While the law prohibits unlicensed entities from practicing medicine, subsequent attorney general opinions have clarified that corporations, including for-profit entities, can employ physicians as long as the physicians retain exclusive control over their professional medical judgment.
- Corporate Practice of Medicine (CPOM): Flexible
- Telehealth prescribing permitted: Yes
- In-person exam required first: No
- Audio-only visits allowed: Yes
- Nurse practitioner authority: Reduced
- Collaborative practice agreement required: Yes
- Good Faith Exam required: Yes
Telehealth prescribing in Virginia
A practitioner can prescribe non-opiate controlled substances via telemedicine after establishing a bona fide practitioner-patient relationship, which can be done remotely. An in-person examination is not required to establish this relationship for most prescriptions, but is required for prescribing opiates. Audio-only communication is permitted for telehealth services but not for establishing a practitioner-patient relationship for prescribing purposes.
Controlled substances in Virginia
Prescribing of Schedule II-VI controlled substances is permitted via telemedicine if a bona fide practitioner-patient relationship has been established in compliance with federal and state law. For Schedule II-V substances, the prescriber must have a physical practice location in Virginia or be able to refer the patient for an in-person examination when needed.
Medical director requirements in Virginia
Virginia requires a medical director, who must be a licensed MD or DO, to oversee clinical operations and ensure regulatory compliance. Remote supervision of nurse practitioners and physician assistants is permitted via telemedicine, provided a documented agreement outlines the terms of the collaboration and oversight.
Nurse practitioner scope and collaborative practice in Virginia
Virginia is a reduced practice state, requiring most Nurse Practitioners to have a written practice agreement with a supervising physician to prescribe and provide medical care. After 9,000 hours of clinical experience, an NP can apply for autonomous practice, but physician oversight is still required for certain procedures like medical aesthetics.
Key operating notes for Virginia
A key compliance factor in Virginia is the establishment of a bona fide practitioner-patient relationship, which can be done via telemedicine, but requires meeting specific criteria including a medical history review and a diagnosis. Patient consent must be obtained and documented before providing telehealth services. Also, Virginia has joined several interstate licensure compacts, facilitating practice across state lines for various healthcare professionals.
Recent regulatory changes in Virginia
No significant recent changes have been identified. The most recent updates to telehealth laws in Virginia appear to have occurred in 2023, with ongoing discussions and minor legislative adjustments since then.
Frequently asked questions
Does Virginia require a PC-MSO structure for my healthcare business?
Virginia has a relatively flexible CPOM framework, but that doesn't mean you can ignore corporate structuring. Depending on your business model — whether telehealth, medspa, IV therapy, or wellness clinic — you may still benefit from a PC-MSO arrangement for liability protection and operational clarity.
Do I need a medical director for my medspa or IV therapy clinic in Virginia?
Yes — Virginia requires physician oversight for medical procedures performed in medspas, IV therapy clinics, and similar brick-and-mortar healthcare establishments. A medical director develops protocols, provides clinical oversight, and ensures regulatory compliance. TrueEval places board-certified medical directors licensed in Virginia who understand both telehealth and in-person practice requirements.
Are Collaborative Practice Agreements required for NPs in Virginia?
Yes, Virginia requires Collaborative Practice Agreements (CPAs) between nurse practitioners and supervising physicians. NPs in Virginia have reduced practice authority, meaning a CPA is necessary for prescriptive authority. TrueEval provides Virginia-specific CPA templates and matches NPs with qualified collaborating physicians.
What are the Good Faith Exam requirements for prescribing in Virginia?
Virginia requires a Good Faith Exam before prescribing medications via telehealth. The GFE can be conducted via telehealth — no in-person visit is required first. Audio-only telehealth is permitted. TrueEval's physician network conducts compliant GFEs for Virginia patients.
What compliance requirements apply to cash-pay healthcare businesses in Virginia?
Cash-pay healthcare operations in Virginia — including telehealth, medspas, IV therapy, and wellness clinics — must still comply with all state medical practice acts, CPOM laws, prescribing regulations, and scope of practice requirements. The main difference is you won't deal with insurance billing compliance, but you must still maintain proper corporate structure, physician oversight, and clinical documentation. TrueEval specializes in cash-pay compliance frameworks for Virginia.