--- title: "Virginia Corporate Practice of Medicine Rules (2026 Guide)" description: "Virginia corporate practice of medicine rules explained: why Virginia is permissive, where PC ownership limits still bite, and what telehealth brands need." slug: virginia-corporate-practice-of-medicine date: 2026-10-18 updated: 2026-10-18 author: MyOrbitHealth Compliance Team category: Compliance cpom: None --- # Corporate Practice of Medicine in Virginia: What Telehealth and Clinic Founders Need to Know Virginia is one of the more permissive states for non-physician founders. As of October 2026, Virginia has no statute that broadly bans corporations from employing physicians, and the Virginia Attorney General is reported to have taken the position that a business entity may employ a physician as long as the physician controls diagnosis and treatment. The real constraint is entity form. A Virginia professional corporation or professional LLC must be owned by people licensed to render the same professional service, so a lay founder cannot hold shares in a medical PC. A non-physician can still own a management company, and in Virginia can often go further. NP founders get an unusual path: Virginia lets experienced nurse practitioners practice without a physician practice agreement, which changes what an NP-owned practice can look like. This is general information, not legal advice. Confirm the current rules with a healthcare attorney licensed in Virginia. *Last reviewed October 2026. State rules change often; statute and case references are summaries, not quotations.* ## Key takeaways - Virginia does not enforce a broad corporate practice of medicine ban; our classification is "None," with the caveat that the rule rests largely on an Attorney General opinion rather than a statute, and at least one secondary source argues for an implicit doctrine, so confirm with counsel. - Secondary sources report that the Virginia Attorney General has said a hospital or business entity may employ a physician if the physician keeps control over diagnosis and treatment and lay interests do not improperly influence clinical judgment. - Virginia professional corporations and professional LLCs may only be owned by individuals or professional entities licensed to render the same professional service. - Va. Code § 54.1-2962 bars physicians from sharing professional fees in exchange for referrals, with an exception for partnerships and group practices. - A physician treating a patient located in Virginia by telemedicine generally needs a Virginia license. ## Does Virginia have a corporate practice of medicine doctrine? Not in the strict sense found in states like California or Texas. Virginia's position comes mainly from an older opinion of the Virginia Attorney General, which secondary sources (including a [DePaul Law Review survey of state CPOM law](https://via.library.depaul.edu/cgi/viewcontent.cgi?article=4152&context=law-review)) describe this way: Virginia statutes and court decisions allow a hospital or other business entity to employ a physician when three conditions hold. The employment agreement lets the physician control the diagnosis and treatment of the patient. The physician's judgment is not improperly influenced by commercial or lay concerns. The physician-patient relationship is not altered. Confirm the opinion's citation and exact conditions from the opinion text before relying on it. The corporate code appears to point the same direction. [Va. Code § 13.1-542.1](https://law.lis.virginia.gov/vacode/title13.1/chapter7/section13.1-542.1/) provides that, unless another law or regulation prohibits it, professional services may be rendered in Virginia by a corporation organized under the general stock or nonstock corporation chapters, not only by a professional corporation. How that provision interacts with the physician licensing rules in Title 54.1 should be confirmed with counsel. An Attorney General opinion is persuasive, not binding, and it addresses employment rather than every form of lay ownership. The safe reading: Virginia permits lay employment of physicians as long as clinical control stays with the physician. ## Who can own a medical practice in Virginia? It depends on which entity you choose. **Professional corporations.** Under [Va. Code § 13.1-543](https://law.lis.virginia.gov/vacode/title13.1/chapter7/section13.1-543/), shareholders of a professional corporation must be individuals or professional business entities duly licensed or otherwise legally authorized to render the same professional service as the corporation. A shareholder who loses that license must promptly sever employment and financial interest, and failure to enforce this is a ground for forfeiture of the corporation's articles. **Professional LLCs.** The [Virginia Professional Limited Liability Company Act, Va. Code § 13.1-1102](https://law.lis.virginia.gov/vacode/title13.1/chapter13/section13.1-1102/), lets a PLLC be organized to render the services of practitioners of the healing arts licensed under Chapter 29 of Title 54.1. Members must be licensed for the same services, and if the PLLC is manager-managed, the manager must be licensed too. **General business entities.** Because of § 13.1-542.1 and the Attorney General's position, a lay-owned corporation employing physicians does not appear to be automatically unlawful in Virginia, though counsel should confirm. Many operators still pair a physician-owned PC with a management company because it documents clinical control cleanly. ## Can nurse practitioners and physician assistants own a practice in Virginia? Our state data lists Virginia NP practice authority as **Restricted** (confirm the current AANP classification), but the statute is more nuanced. Under [Va. Code § 54.1-2957](https://law.lis.virginia.gov/vacode/title54.1/chapter29/section54.1-2957/), an NP generally practices under a written or electronic practice agreement with a patient care team physician. An NP who has completed a required period of full-time clinical experience may practice without a practice agreement once a patient care team physician or attesting NP provides an attestation. The Board of Nursing's [autonomous practice regulation, 18VAC90-30-86](https://law.lis.virginia.gov/admincode/title18/agency90/chapter30/section86/), implements the attestation. Confirm the current experience threshold with the Board of Nursing. Autonomous NPs must still consult and collaborate with other providers and keep a referral plan for complex cases. PAs practice on a patient care team under a practice agreement, and a physician may collaborate with no more than six PAs at a time under [Va. Code § 54.1-2952](https://law.lis.virginia.gov/vacode/title54.1/chapter29/section54.1-2952/). Virginia law includes a pathway in § 54.1-2952.01 for experienced PAs to practice without an agreement, but its effective date is contingent, so treat it as pending and confirm whether it is in force. On ownership, the same-profession rule applies. An NP can own a professional entity organized to render nursing services, but an NP-owned entity should not hold itself out as rendering physician services. A newer NP who still needs a patient care team physician will need a [collaborating physician](/blog/collaborating-physician) relationship regardless of who owns the entity. ## How does the friendly PC-MSO model work in Virginia? In Virginia the [friendly PC-MSO model](/blog/friendly-pc-mso-model) is a choice, not a necessity. Founders use it for clean separation: a physician-owned PC or PLLC holds the clinical side, and the founder's MSO provides technology, marketing, billing, staff, and real estate under a management services agreement. Watch fee structure. [Va. Code § 54.1-2962](https://law.lis.virginia.gov/vacode/title54.1/chapter29/section54.1-2962/) bars a physician from knowingly and willfully sharing a professional fee with another physician in exchange for a referral, with an exception for partnerships and group practices dividing fees among members. [Va. Code § 54.1-2962.1](https://law.lis.virginia.gov/vacode/title54.1/chapter29/section54.1-2962.1/) separately bars soliciting or receiving remuneration for referrals to facilities. A management fee that tracks referrals or volume still draws scrutiny, so flat or cost-plus fair-market-value fees remain the conservative default. ## What does this mean for a telehealth brand serving Virginia patients? Licensure is the gating issue, not ownership. The Virginia Board of Medicine has stated in published guidance (confirm it is still current) that the practice of medicine occurs where the patient is located, so the provider must be licensed in the patient's state. Virginia has no out-of-state telehealth registration. [Va. Code § 54.1-2901](https://law.lis.virginia.gov/vacode/title54.1/chapter29/section54.1-2901/) contains a limited exemption for out-of-state physicians providing continuity of care to an existing patient located in Virginia, subject to conditions you should confirm, plus a separate behavioral health provision. Neither supports a new-patient telehealth business, so plan on Virginia licenses for every clinician who treats Virginia patients. See our [telehealth licensing by state guide](/blog/telehealth-licensing-by-state). Practically, most multistate brands serve Virginia through the same MSO and affiliated PC they use elsewhere, staffed with Virginia-licensed clinicians, rather than building a Virginia-only lay-owned entity. ## Virginia CPOM at a glance | Topic | Virginia (as of October 2026) | |---|---| | CPOM enforcement | None (no broad ban; clinical control must stay with physicians) | | Primary legal basis | Virginia Attorney General opinion (as described in secondary sources); Va. Code § 13.1-542.1 | | Professional entity options | PC (Va. Code § 13.1-543 et seq.), PLLC (Va. Code § 13.1-1102 et seq.); general corporations appear able to employ physicians (confirm) | | Fee-splitting rule | Va. Code § 54.1-2962 bars fee sharing for referrals; group practice exception | | NP practice authority | Restricted per our table; autonomous practice after required experience and attestation | | Out-of-state telehealth licensing | No registration; Virginia license required, narrow continuity-of-care exemption | | Typical structure for non-physician founders | MSO plus physician-owned PC/PLLC, or lay entity employing physicians with documented clinical control | ## Frequently asked questions ### Can a non-physician own a medical practice in Virginia? A non-physician cannot own shares in a Virginia professional corporation or professional LLC formed to provide medical services. However, Virginia does not appear to broadly prohibit a business entity from employing physicians, provided the physician controls diagnosis and treatment. Many founders still use an MSO with a physician-owned PC for clarity. ### Does Virginia enforce the corporate practice of medicine doctrine? Not broadly. Secondary sources report that the Virginia Attorney General has said a hospital or business entity may employ a physician if the physician keeps control of clinical decisions and lay interests do not improperly influence medical judgment. Ownership limits still apply to professional corporations and PLLCs. ### Can a nurse practitioner own a practice in Virginia? An NP can own a professional entity organized to provide nursing services. NPs with the required full-time clinical experience can practice without a physician practice agreement after an attestation (confirm the current threshold); less experienced NPs need a patient care team physician. ### Do out-of-state doctors need a Virginia license for telehealth? Generally yes. The Board of Medicine's published guidance has treated the practice of medicine as occurring where the patient is located, and Virginia has no telehealth registration. A narrow statutory exemption covers continuity of care for existing patients, subject to conditions that should be confirmed. ### Is percentage-based MSO compensation allowed in Virginia? Virginia's fee-splitting statute targets fee sharing in exchange for referrals, so it does not expressly ban every percentage fee. Fees that vary with referrals or patient volume raise risk under state and federal law, so most counsel prefer flat, fair-market-value management fees. ## Sources - [Va. Code § 13.1-543, Professional Corporations: Definitions](https://law.lis.virginia.gov/vacode/title13.1/chapter7/section13.1-543/) - [Va. Code § 13.1-1102, Virginia Professional Limited Liability Company Act](https://law.lis.virginia.gov/vacode/title13.1/chapter13/section13.1-1102/) - [Va. Code § 54.1-2962, Division of fees among physicians prohibited](https://law.lis.virginia.gov/vacode/title54.1/chapter29/section54.1-2962/) - [Va. Code § 54.1-2957, Licensure and practice of advanced practice registered nurses](https://law.lis.virginia.gov/vacode/title54.1/chapter29/section54.1-2957/) - [Va. Code § 54.1-2952, Patient care teams and physician assistants](https://law.lis.virginia.gov/vacode/title54.1/chapter29/section54.1-2952/) - [Va. Code § 54.1-2901, Exceptions and exemptions generally](https://law.lis.virginia.gov/vacode/title54.1/chapter29/section54.1-2901/) - [DePaul Law Review, Vol. 70, Issue 1 (2020), survey of state CPOM law](https://via.library.depaul.edu/cgi/viewcontent.cgi?article=4152&context=law-review) For how Virginia compares with every other state, see our [50-state corporate practice of medicine guide](/blog/corporate-practice-of-medicine-50-state-guide). ## Launch in Virginia on a structure that is already built MyOrbitHealth can [form a PC-MSO structure](/pc-mso-formation) for your brand, supply a [physician PC owner or collaborating physician](/physician-pc-owner), or let you launch on its existing MSO / friendly-PC structure with 2,400+ licensed providers making every clinical decision. MyOrbitHealth does not practice medicine, charges a flat platform fee with no revenue share, and works month-to-month. [Book a call](https://myorbithealth.com/book) to map your Virginia launch. ```html ```