Hawaii's corporate practice of medicine (CPOM) status is limited or unsettled. We are not aware of a Hawaii statute that specifically prohibits the corporate practice of medicine, and we found no recent enforcement history. What Hawaii does have is the Hawaii Professional Corporation Act, HRS Chapter 415A, which controls who can own and run a professional corporation. Its rules, as reported, are a little different from most states: shares must be held by licensees, but not every director and officer must be licensed.
Bottom line for a non-physician founder: you should not expect to hold shares in a Hawaii medical professional corporation, and the conservative structure is a physician-owned PC plus an MSO. For NP founders, Hawaii is one of the most favorable states in the country. NPs have full practice authority, so NP-led models are straightforward once licensing is in place. Licensing, not CPOM, is usually the harder Hawaii problem for telehealth brands.
This is general information, not legal advice. Confirm the current rules with a healthcare attorney licensed in Hawaii. Last reviewed October 2026. State rules change often; statute and case references are summaries, not quotations.
Key takeaways
- We are not aware of a Hawaii statute that specifically addresses the corporate practice of medicine, so we classify its CPOM status as limited or unsettled.
- Hawaii's Professional Corporation Act generally limits share ownership in a professional corporation to individuals authorized to render the corporation's professional service.
- The Act, as published in a 2017 compilation, also requires a minimum portion of directors and most officers to be licensees, but not all of them; confirm the current text.
- Hawaii nurse practitioners have full practice authority under the AANP classification.
- Our state data shows no Hawaii telehealth registration for out-of-state physicians, so clinicians treating patients in Hawaii should generally plan on a Hawaii license.
Does Hawaii have a corporate practice of medicine doctrine?
Not in statute, as far as we could find. A law firm analysis quoted by the medical liability insurer MIEC states that Hawaii does not have a statute specifically applicable to the corporate practice of medicine, while noting that Chapter 415A still governs medical professional corporations. That analysis may be dated, so confirm there has been no recent change. We did not find a Hawaii court decision or attorney general opinion adopting a common-law CPOM ban either.
That leaves Hawaii in a familiar middle position:
- No express ban that we found on a business entity employing physicians.
- Ownership limits on professional corporations under Chapter 415A.
- Licensing and discipline. Only Hawaii-licensed physicians can practice medicine on Hawaii patients, and the Hawaii Medical Board can discipline physicians whose judgment is compromised.
Because we found no modern Hawaii case law testing the doctrine, and no Hawaii Medical Board position on it, we treat it as unsettled rather than absent. A structure that gives non-physicians control over clinical decisions would be the most likely target if that changes.
Who can own a medical practice in Hawaii?
Professional corporations. The Hawaii Professional Corporation Act sets the rules. In general terms, based on a 2017 compilation of the Act (confirm the current text with Hawaii counsel):
- A professional corporation may render professional services in Hawaii only through individuals permitted to render those services in Hawaii.
- Shares may be issued only to individuals authorized by law to render the relevant professional service.
- Only a portion of the directors, and most but not all officers, must be qualified persons. In the 2017 compilation, the threshold is at least half of the directors and all officers other than the secretary and treasurer.
- A professional corporation may be organized to render more than one professional service, subject to each profession's licensing laws.
- HRS § 415A-11 preserves each professional's responsibility for the services they render.
The board and officer rule is the Hawaii quirk. On that reading, a non-licensed person could serve as a minority of the directors or in certain officer roles of a medical PC. They still could not own shares, and they should never control clinical decisions.
Other entities. With no express CPOM ban that we found, a business entity employing Hawaii-licensed physicians is not clearly prohibited. Hospitals and health systems employ physicians directly. Have Hawaii counsel review any non-PC model before launch.
Can nurse practitioners and physician assistants own a practice in Hawaii?
Nurse practitioners. Hawaii is a full practice authority state under the AANP classification. APRNs can generally evaluate, diagnose, treat, and prescribe without a physician collaboration agreement; confirm any current transition-to-practice requirements with Hawaii counsel. That makes Hawaii a strong state for NP-led primary care, behavioral health, and chronic care programs. Because Chapter 415A permits professional corporations for licensed professions, an APRN can generally own a professional entity rendering nursing services. Confirm the specific entity type with counsel.
Physician assistants. Hawaii PAs have generally practiced under a physician relationship rather than independently. A PA-led model should plan for a documented physician relationship before PAs see patients. Confirm current requirements with the Hawaii Medical Board.
How does the friendly PC-MSO model work in Hawaii?
The friendly PC-MSO model works cleanly in Hawaii. A Hawaii-licensed physician owns the shares of the PC. The PC employs or contracts the clinicians and makes every clinical decision. Your MSO provides technology, marketing, billing support, and operations under a management services agreement.
Hawaii-specific points:
- Board composition. Chapter 415A, as reported, allows some non-licensed directors and officers. Use that flexibility carefully. Putting MSO executives on the PC board invites a control argument. Keeping the PC board fully physician-led is the cleaner choice.
- Fees. We did not confirm a Hawaii fee-splitting statute that targets management fees. A fair market value flat or cost-plus fee is still the safer design, and federal anti-kickback and Stark rules apply to federal program revenue.
- Island logistics. Hawaii patients may need in-person follow-up, labs, or imaging on a specific island. Build local referral and lab relationships into your operations plan early.
What does this mean for a telehealth brand serving Hawaii patients?
Hawaii's rules apply when the patient is physically in Hawaii during the visit, wherever your company or clinician is located.
Licensing is the real gate. Our state data shows no Hawaii telehealth registration for out-of-state physicians, so plan on clinicians holding a full Hawaii license, and confirm with counsel whether any narrow exception or compact pathway applies to your program. Factor licensing timelines into any Hawaii launch, and see our telehealth licensing by state guide for planning across your footprint.
Practical structure: Hawaii-licensed physicians or full-practice APRNs, a physician-owned PC (often your multistate PC with a Hawaii-licensed physician), and an MSA with clear clinical control provisions. Scheduling also matters. Hawaii does not observe daylight saving time, so availability windows shift relative to the mainland twice a year.
Hawaii CPOM at a glance
| Topic | Hawaii (as of October 2026) |
|---|---|
| CPOM enforcement | Limited or unsettled |
| Primary legal basis | No CPOM-specific statute identified; Hawaii Professional Corporation Act (HRS Ch. 415A) |
| Professional entity options | Professional corporation (licensed shareholders; some directors and officers must be licensed); other entities not clearly barred |
| Fee-splitting rule | No Hawaii-specific rule confirmed; use fair market value fees |
| NP practice authority | Full |
| Out-of-state telehealth licensing | No registration in our data; plan on a full Hawaii license |
| Typical structure for non-physician founders | Physician-owned PC plus MSO |
Frequently asked questions
Does Hawaii have a corporate practice of medicine law?
We are not aware of a Hawaii statute that specifically addresses the corporate practice of medicine, though the analysis reporting this may be dated. Ownership of medical professional corporations is still generally limited to licensees under HRS Chapter 415A.
Can a non-physician own a medical practice in Hawaii?
A non-physician generally cannot hold shares in a Hawaii medical professional corporation. Non-physicians typically own the management services organization that supports a physician-owned PC.
Can non-physicians serve on the board of a Hawaii professional corporation?
Yes, within limits. Chapter 415A, as reported, requires a minimum portion of the directors and most officers to be qualified licensees. Confirm the current threshold with Hawaii counsel.
Can nurse practitioners practice independently in Hawaii?
Generally yes. Hawaii is a full practice authority state, so APRNs can generally practice without a physician collaboration agreement. Confirm any current transition-to-practice requirements with Hawaii counsel.
Do out-of-state doctors need a Hawaii license for telehealth?
Generally yes. Our state data shows no Hawaii telehealth registration for out-of-state physicians, so clinicians treating patients located in Hawaii should plan on a Hawaii license. Confirm whether any narrow exception applies.
Sources
- HRS Chapter 415A, Hawaii Professional Corporation Act (Hawaii Legislature)
- HRS § 415A-11, Responsibility for professional services (Justia)
- MIEC, FAQ: Medispas
- ABA Health Lawyer, "What Is . . . the Corporate Practice of Medicine and Fee-Splitting?"
See how Hawaii compares with every other state in our corporate practice of medicine 50-state guide.
Launch in Hawaii on a structure that is already built
MyOrbitHealth can form a PC-MSO structure for your brand through our PC-MSO formation service, or supply a physician PC owner or collaborating physician through our physician PC owner services. You can also launch on our existing MSO / friendly-PC structure, where 2,400+ licensed providers make every clinical decision and MyOrbitHealth does not practice medicine. Book a call to scope it.

