# Starting a virtual clinic in Indiana: 2026 telehealth requirements

To treat patients located in Indiana by telehealth, a practitioner must hold the proper Indiana license. Indiana used to offer a telehealth certification for out-of-state practitioners under IC 25-1-9.5-9, but CCHP reports that effective July 1, 2024 all previously issued telehealth certificates and telehealth facility certificates were permanently terminated, and practitioners and their employers no longer apply for or renew them. There is no replacement registration. Indiana is a member of the Interstate Medical Licensure Compact, so physicians holding a qualifying principal license elsewhere can obtain an Indiana license through the expedited compact process. Nurse practitioners are in AANP's reduced practice category, so Indiana NPs work under a collaborative arrangement with a physician. Indiana's corporate practice of medicine posture is moderate: the prohibition is codified in the medical practice statute at IC 25-22.5, there is little case law interpreting it, and fee-splitting that is not proportional to services rendered is prohibited. This page covers licensing, the end of the certification program, ownership structure, NP scope, controlled substances and pharmacy fulfillment for an Indiana telehealth brand, citing CCHP and the two 50-state CPOM guides. This is general information, not legal advice.

## Summary

- IMLC: Member
- Out-of-state telehealth: Full license required (No (telehealth certification for out-of-state practitioners terminated July 1, 2024; Indiana license required))
- NP practice: Reduced practice
- CPOM: Moderate
- PA Compact: Not enacted
- APRN Compact: Not enacted
- Data as of: 2026-10-05

## Requirements

| Requirement | Rule in Indiana | What it means for a brand |
| --- | --- | --- |
| Physician licensure | A practitioner who establishes a relationship with or decides whether to prescribe for a patient located in Indiana is practicing in Indiana and must hold an Indiana license, available to qualifying physicians through the Interstate Medical Licensure Compact. | Every physician who treats Indiana patients needs an Indiana license, with the compact as the fastest route. |
| Out-of-state telehealth | Indiana's telehealth certification for out-of-state practitioners under IC 25-1-9.5-9 was permanently terminated effective July 1, 2024, and no registration replaced it. | There is no provisional path; remove any reliance on old telehealth certificates and license the roster. |
| Nurse practitioner practice | AANP classifies Indiana as reduced practice, requiring a career-long regulated collaborative agreement for NP care. | Each Indiana NP needs a collaborating physician and written arrangement before seeing Indiana patients. |
| Practice ownership (CPOM) | Indiana's corporate practice prohibition is codified in IC 25-22.5, non-physician ownership of a medical practice is not permitted, and fee-splitting not proportional to services rendered is prohibited. | Use an MSO with a fair market value fee and a physician-owned PC or PLLC for all clinical services. |
| Controlled substances | Follows federal DEA telemedicine rules; state PDMP and prescribing rules apply. | The DEA/HHS fourth temporary extension of telemedicine flexibilities runs through December 31, 2026; confirm status on dea.gov and with the Indiana boards before prescribing controlled substances remotely. |
| Pharmacy fulfillment | A pharmacy shipping into Indiana needs an Indiana resident or non-resident pharmacy license. | Verify each fulfillment pharmacy's Indiana license before routing Indiana prescriptions. |

## Do you need an Indiana medical license to provide telehealth?

Yes. CCHP's cross-state licensing summary, updated June 2026, states that a practitioner must hold a proper Indiana license to practice in Indiana, including through telehealth, and the page's at-a-glance box lists no limited licensure exceptions and no telehealth-specific registration process. Indiana law also settles the location question explicitly. Under IC 25-1-9.5 as summarized by CCHP, a practitioner physically outside Indiana is treated as providing care in Indiana when they establish a provider-patient relationship with someone located in Indiana or decide whether to issue that person a prescription. That practitioner agrees to the jurisdiction of Indiana courts and Indiana law for any claim arising from the care, waives the law of other jurisdictions for those claims, and the waiver extends to the practitioner's employer or contractor.

The out-of-state certification is gone. CCHP, citing IC 25-1-9.5-9 and a June 7, 2024 notice from the Indiana Professional Licensing Agency, reports that effective July 1, 2024 all previously issued telehealth certificates and telehealth facility certificates were terminated permanently rather than allowed to expire. Practitioners and the entities that employ or contract them no longer need to obtain the certification, and existing certificates no longer renew with the practitioner's license. A brand that still lists Indiana telehealth certificates in its credentialing file is relying on authorization that no longer exists.

Indiana is a member of the Interstate Medical Licensure Compact, which CCHP lists in its licensure compacts section, so a physician with a qualifying principal license in another compact state can obtain a full Indiana license on the expedited timeline. Confirm current issuing status on the IMLCC site. CCHP does not describe a consultation exception in the Indiana cross-state section.

For a brand, the roster rule is simple and strict: every physician, physician assistant and nurse practitioner who treats Indiana patients holds an Indiana license, and the jurisdiction clause means your professional entity should expect Indiana law and courts to govern any Indiana claim. The compact is the fastest route for physicians; NPs need an Indiana APRN license through the Indiana State Board of Nursing.

## Indiana corporate practice of medicine and MSO rules

Our dataset classifies Indiana's corporate practice of medicine doctrine as moderate. Both 50-state guides agree that the prohibition is statutory. The Permit Health guide reports that the doctrine is codified in Indiana's medical practice statute and cites IC 25-22.5-1-1.1(a)(1) and (a)(2) for the definition of practicing medicine, along with IC 25-22.5-1-2(c) and IC 25-22.5-8-1. It notes that telemedicine was added to the definition of medical practice in 1996 and that no specific case law interprets the corporate practice provision. The MedPath guide also cites IC 25-22.5, lists the permitted entity types as a professional corporation or PLLC, and states that non-physician ownership is not permitted.

The moderate label reflects a clear statutory rule with little enforcement history rather than a weak rule. A non-clinician brand should not own the Indiana medical practice. The structure that fits the statute is a management services organization owned by the brand that provides the platform, intake, marketing, scheduling, billing support and administrative staff under a written management agreement, paired with a professional corporation or PLLC owned by an Indiana-licensed physician that employs or contracts the clinicians, holds the patient relationships and controls all clinical decisions.

Two Indiana-specific points shape the management agreement. First, Permit Health reports that Indiana prohibits fee-splitting in any way that is not proportional to the professional services rendered, so the MSO fee should be fair market value for the services the MSO actually delivers rather than a percentage of professional revenue. Second, the MedPath guide flags House Bill 1666, signed May 6, 2025, which it describes as giving the Indiana attorney general authority over health care market transactions and adding ownership reporting requirements. Check the current rules under that law before closing any acquisition or affiliation involving an Indiana practice, and expect ownership of the professional entity to be reportable.

## Indiana nurse practitioner scope of practice

AANP's state practice environment map, updated May 2026, classifies Indiana as a reduced practice state. Under AANP's definition, reduced practice means state law limits at least one element of NP practice and requires a career-long regulated collaborative agreement with another health provider, or limits the setting of one or more elements of practice. For an Indiana NP that generally means a collaborative practice arrangement with a physician, with prescriptive authority tied to that arrangement.

For an asynchronous telehealth program, each Indiana NP needs an Indiana APRN license and a collaborating physician who is authorized in Indiana, with the written arrangement in place before the first Indiana encounter. Because Indiana treats an out-of-state practitioner as practicing in Indiana the moment a provider-patient relationship or prescribing decision involves an Indiana patient, an NP licensed only elsewhere cannot cover Indiana patients under a physician's license. The sources we reviewed did not state transition-to-practice hours or the detailed terms of the collaborative arrangement, so confirm current requirements with the Indiana State Board of Nursing.

## How Indiana compares with its neighbors

| State | IMLC | Out-of-state telehealth | NP practice | CPOM |
| --- | --- | --- | --- | --- |
| Indiana | Member | Full license required | Reduced practice | Moderate |
| [Illinois](https://myorbithealth.com/compliance/illinois) | Member | Limited exceptions only | Reduced practice | Strong |
| [Ohio](https://myorbithealth.com/compliance/ohio) | Member | Limited exceptions only | Reduced practice | Limited or unsettled |
| [Kentucky](https://myorbithealth.com/compliance/kentucky) | Member | Full license required | Reduced practice | Limited or unsettled |

## Federal rules that apply to every virtual clinic

### DEA telemedicine prescribing

On December 31, 2025, DEA and HHS published the fourth temporary extension of the telemedicine flexibilities, effective January 1, 2026 through December 31, 2026. Under it a DEA-registered practitioner may prescribe Schedule II through V controlled substances by audio-video telemedicine without a prior in-person evaluation, subject to state law. DEA's special registration final rule was sent to the White House Office of Information and Regulatory Affairs on August 25, 2026 and was not published as of this review. Plan for the flexibilities to change on January 1, 2027 and confirm status on dea.gov.

### HIPAA and breach notification

A telehealth brand that creates, receives or stores protected health information needs a business associate agreement with every vendor that touches it, and the HIPAA Breach Notification Rule (45 CFR 164.400 through 164.414) requires notice to affected individuals without unreasonable delay and no later than 60 days after discovery, with HHS notified within 60 days for breaches affecting 500 or more people. MyOrbitHealth includes a BAA in every contract.

### FTC Health Breach Notification Rule

Health apps and connected services that are not HIPAA covered entities fall under the FTC's Health Breach Notification Rule (16 CFR Part 318), amended in 2024 to cover most consumer health apps. A storefront that collects health information outside the clinical record may be covered even where HIPAA is not.

### LegitScript certification for advertising

Google, Meta and Microsoft rely on LegitScript healthcare merchant certification before serving telehealth ads that can result in a prescription. Certification is national, not per state, but the file includes the licensure and corporate-structure evidence described on this page. MyOrbitHealth prepares, files and manages the application through approval; LegitScript decides, and certification is not guaranteed.

## How MyOrbitHealth launches a compliant virtual clinic in Indiana

### Providers already licensed in Indiana

The MyOrbitHealth provider network covers all 50 states with 2,400+ board-certified MD, DO, NP and PA providers across 38+ specialties, credentialed to the NCQA standard with monthly OIG-LEIE and SAM.gov exclusion screening and continuous license monitoring. A Indiana patient is routed to a provider licensed in Indiana, at an average response under six minutes during business hours.

### Structure held inside the network

Care is delivered by the network's physician-owned professional entity under a management services structure, so a brand contracts with the platform and never owns a medical practice. That is how a non-clinician brand serves Indiana patients without taking on corporate practice of medicine exposure directly. Your own counsel should still review the arrangement for Indiana.

### Modality and prescribing rules enforced at routing

Orbit Intake and OrbitRx encode state modality and prescribing rules, so an intake that Indiana requires to be synchronous never reaches a provider as an asynchronous case, and OrbitRx delivers EPCS with two-factor identity proofing through Surescripts for any controlled substance a provider decides to prescribe.

### Pharmacy, labs and LegitScript

Prescriptions route to a LegitScript-certified network of 503A compounding and retail pharmacies licensed to ship into Indiana, with cold-chain delivery and 0% medication markup. Orbit Labs draws samples three ways through Quest Diagnostics or Labcorp walk-in, Tasso at-home kits or mobile phlebotomy. Managed LegitScript certification typically takes days once filed, not months; LegitScript decides. Brands go live in days on a flat scoped platform fee with no revenue share, and the brand owns its patients and data.

Dataset (CSV): https://myorbithealth.com/data/state-compliance-2026.csv · 2026 report: https://myorbithealth.com/blog/state-telehealth-compliance-report-2026

## FAQ

### What are the requirements to start a virtual clinic in Indiana?

You need Indiana-licensed physicians and NPs for every Indiana patient, since the state's out-of-state telehealth certification ended on July 1, 2024 and nothing replaced it. NPs work under a collaborative arrangement with a physician. Clinical services must sit in a physician-owned professional corporation or PLLC with the brand operating as an MSO, because Indiana's corporate practice prohibition is statutory and fee-splitting must be proportional to services. Pharmacies shipping into Indiana need an Indiana license, and controlled substance prescribing follows federal DEA rules plus Indiana PDMP requirements.

### Do I need an Indiana medical license to provide telehealth?

Yes. CCHP reports that a practitioner must hold a proper Indiana license to practice in Indiana, including by telehealth, and that a practitioner outside Indiana is treated as practicing in Indiana when they establish a relationship with or decide whether to prescribe for someone located in Indiana. The former out-of-state telehealth certification under IC 25-1-9.5-9 was permanently terminated effective July 1, 2024.

### Is Indiana in the Interstate Medical Licensure Compact?

Yes. CCHP and the IMLCC participating states list both show Indiana as a member, so physicians with a qualifying principal license in another compact state can obtain an Indiana license through the expedited process. Confirm current issuing status on the IMLCC site.

### Is Indiana a corporate practice of medicine state?

Yes, with a moderate classification. The prohibition is codified in Indiana's medical practice statute at IC 25-22.5, non-physician ownership of a medical practice is not permitted, and fee-splitting that is not proportional to services rendered is prohibited, per the two 50-state guides. There is little case law, but the statute is clear enough that brands should use an MSO paired with a physician-owned professional entity.

### Can nurse practitioners practice independently in Indiana?

Not under the general rule. AANP's May 2026 map classifies Indiana as a reduced practice state, meaning NPs need a career-long regulated collaborative agreement with another provider. Plan for a collaborating physician and written arrangement for every Indiana NP.

### Can controlled substances be prescribed by telehealth in Indiana in 2026?

At the federal level, the DEA/HHS fourth temporary extension of telemedicine flexibilities runs through December 31, 2026; confirm status on dea.gov. Indiana treats a prescribing decision for an Indiana patient as practice in Indiana, so the prescriber needs an Indiana license, and Indiana PDMP and prescribing rules apply. The sources we reviewed did not state a separate in-person rule, so confirm with the Indiana Medical Licensing Board before launching.

### How fast can a telehealth brand launch in Indiana?

MyOrbitHealth already has providers licensed in Indiana within its network of 2,400+ board-certified MD, DO, NP and PA providers across 38+ specialties and all 50 states, with EPCS-ready e-prescribing and a LegitScript-certified pharmacy network. Brands go live in days on the hosted platform. Managed LegitScript certification is filed for you and is typically approved in days once filed, though LegitScript decides and approval is not guaranteed.

_This is general information, not legal advice._

## Sources

- [CCHP: Indiana cross-state licensing](https://www.cchpca.org/indiana/?category=professional-requirements&topic=cross-state-licensing)
- [IMLCC participating states](https://www.imlcc.com/participating-states/)
- [AANP state practice environment](https://www.aanp.org/advocacy/state/state-practice-environment)
- [FSMB: Telemedicine policies by state](https://www.fsmb.org/siteassets/advocacy/key-issues/telemedicine_policies_by_state.pdf)
- [MedPath Compliance: CPOM 50-state guide](https://www.medpathcompliance.com/post/corporate-practice-of-medicine-cpom-50-state-guide)
- [Permit Health: Corporate practice of medicine 50-state guide](https://www.permithealth.com/post/the-corporate-practice-of-medicine-50-state-guide)

_Source: https://myorbithealth.com/compliance/indiana · facts reviewed 2026-10-18_