Starting a virtual clinic in Maryland: 2026 telehealth requirements

Yes. Maryland's Health Occupations Article, section 1-1005, requires a health care practitioner who provides services through telehealth to be licensed, certified or otherwise authorized in Maryland when the patient is located in the state. The Board of Physicians' telehealth regulation, COMAR 10.32.05.03, confirms that telehealth practice falls under the board's rules whenever the practitioner, the patient or both are in Maryland. Each health occupation board applies the same patient-location principle through its own chapter of COMAR, so NPs, PAs and other licensees are covered the same way.

There is no registration pathway. Health Occupations 14-301 requires a physician to be licensed by the board before practicing medicine in Maryland, and 14-302 lists the exceptions. The ones relevant to a virtual clinic are narrow: an out-of-state physician with an active, unrestricted license who consults with a Maryland-licensed physician about a particular patient without directing that patient's care; a physician in an adjoining state who prescribes home health services for a Maryland resident after an in-person exam in that adjoining state and without a Maryland office; plus federal employment and visiting sports team exceptions. None of these supports direct-to-consumer visits with Maryland residents.

The realistic routes to a Maryland license are the Interstate Medical Licensure Compact and the Board of Physicians' expedited license pathways. CCHP lists Maryland as an IMLC member, so a physician who qualifies through a state of principal license can obtain a full Maryland license through the compact. The board's expedited pathways page covers certain out-of-state physicians outside the compact process.

For a brand, this means every physician, NP and PA who treats Maryland patients must appear on the Maryland roster with an active license before launch. MyOrbitHealth's network of 2,400+ providers across all 50 states includes Maryland-licensed clinicians, so a brand does not need to run its own licensing program to open the state.

Maryland's corporate practice of medicine doctrine is moderate. It rests on common law and board policy, not on an explicit statute. The MedPath guide classifies Maryland as a CPOM state under common law, with ownership limited to exempt categories and fee-splitting rules in force. The PermitHealth guide describes the doctrine as somewhat ambiguous and notes that enforcement is most likely when a corporate employer interferes with a physician's medical judgment. Both guides cite the Board of Physicians' long-standing position that a corporation may employ a physician only if it is a professional service corporation, a hospital or a health maintenance organization, and both note that Maryland's statutes expressly exempt hospitals.

A non-clinician brand should therefore use the MSO plus physician-owned professional entity model in Maryland rather than employing clinicians directly. The brand or its platform partner operates a management services organization that holds the technology, marketing, non-clinical staff and administrative contracts. A Maryland-licensed physician owns the professional service corporation that employs or contracts the physicians, NPs and PAs. The management agreement should charge a fair-market-value fee for defined services rather than a share of professional revenue, because the PermitHealth guide notes Maryland's fee-splitting prohibitions reach physicians and other licensed professionals.

Because the doctrine is enforced around interference with judgment, the drafting detail that matters most is who controls clinical protocols, prescribing decisions, referral choices and the hiring and firing of clinicians. Those belong to the professional entity. MyOrbitHealth supplies the medical layer through licensed providers under an MSO and friendly professional corporation structure, so a brand entering Maryland keeps ownership of its customers, records and data while the clinical entity holds the licenses. Confirm the current board position with Maryland counsel before signing ownership documents.

AANP classifies Maryland as a full practice state in its May 2026 practice environment map. In AANP's definition, full practice means NPs can evaluate patients, diagnose, order and interpret tests, and initiate and manage treatments, including prescribing medications and controlled substances, under the exclusive licensure authority of the state board of nursing. The AANP Maryland page confirms the category and points to the Nurse Practice Act on the Maryland Board of Nursing site.

Maryland's full practice authority law from 2015 replaced the earlier collaboration attestation with a mentorship requirement for first-time certificants. According to the Board of Nursing's initial advanced practice application and its notice of proposed action on nurse practitioner practice, an applicant who has never been certified as an NP in Maryland or another state must name a mentor, a Maryland-licensed NP or physician with at least three years of experience, for an 18-month period that runs from the date the board receives the application. No written agreement is filed, and NPs already certified elsewhere are exempt. Confirm the current regulation text with the Board of Nursing before relying on these details.

For an asynchronous or video-first clinic, an established Maryland NP can own the chart without physician collaboration. Only newly certified NPs need a named mentor, which a network with experienced Maryland clinicians can supply.