# Starting a virtual clinic in Michigan: 2026 telehealth requirements

A brand that wants to treat patients located in Michigan needs clinicians licensed in Michigan. The Public Health Code offers no telehealth registration; the exemptions in MCL 333.16171 cover an out-of-state practitioner called in for consultation in an exceptional circumstance and a practitioner who lives along Michigan's land border and keeps no office in the state, neither of which supports a direct-to-consumer clinic. Michigan is a member of the Interstate Medical Licensure Compact, which gives eligible physicians an expedited full license. Nurse practitioners are classified by AANP as restricted practice, so NP staffing requires physician supervision or delegation. Corporate practice of medicine is a strong doctrine in Michigan, anchored in section 251 of the Business Corporation Act and two Attorney General opinions, so the clinical entity must be a professional corporation or PLLC owned by licensed physicians. This page covers the licensure rule and its exemptions, the CPOM and MSO structure, NP scope, and the telehealth prescribing statute. This is general information, not legal advice.

## Summary

- IMLC: Member
- Out-of-state telehealth: Full license required (MCL 333.16171 exceptions only) (No (full license required; exceptional-circumstance consultation and border exceptions only))
- NP practice: Restricted practice
- CPOM: Strong
- PA Compact: Enacted
- APRN Compact: Not enacted
- Data as of: 2026-10-05

## Requirements

| Requirement | Rule in Michigan | What it means for a brand |
| --- | --- | --- |
| Physician licensure | Telemedicine must be provided by a professional licensed, registered or otherwise authorized in the state where the patient is located (MCL 500.3476; Public Health Code), and there is no telehealth license or registration. | Every clinician who treats Michigan patients for the brand must hold a Michigan license before the first visit. |
| Out-of-state telehealth | MCL 333.16171 exempts only an out-of-state practitioner called in for consultation in an exceptional circumstance, a border resident with no Michigan office, and categories such as military, disaster, lecturer and athletic team practitioners. | None of the exemptions supports direct-to-consumer care, so out-of-state physicians should use the IMLC to obtain a full Michigan license. |
| Nurse practitioner practice | AANP classifies Michigan as restricted practice, which requires career-long physician supervision, delegation or team management. | Every NP on the Michigan roster needs a Michigan-licensed supervising physician inside the professional entity, with prescribing delegated and documented. |
| Practice ownership (CPOM) | Section 251(1) of the Business Corporation Act and Attorney General Opinions 6592 (1989) and 6770 (1993) bar ordinary corporations from practicing medicine or employing physicians for licensed services; practice runs through a PC or PLLC owned by licensees. | The clinical entity must be a physician-owned PC or PLLC, with the brand operating as an MSO under a fair-market-value fee. |
| Controlled substances | MCL 333.16285 lets a telehealth provider prescribe only as a prescriber within scope, with referral to geographically accessible care when needed and availability for follow-up, and MCL 333.7303a requires a bona fide prescriber-patient relationship with follow-up monitoring before prescribing Schedule 2 to 5 controlled substances. Federal DEA telemedicine rules also apply. | Design the controlled substance workflow around a documented bona fide relationship, follow-up monitoring and local referral paths, and confirm MAPS obligations with the state. |
| Pharmacy fulfillment | A pharmacy shipping into Michigan needs a Michigan resident or non-resident pharmacy license. | Use a pharmacy network that already holds Michigan licensure; MyOrbitHealth routes prescriptions to a LegitScript-certified pharmacy network that ships to all 50 states. |

## Do you need a Michigan medical license to provide telehealth?

Yes. CCHP's Michigan page quotes both the Insurance Code (MCL 500.3476) and the Medicaid provider manual for the same rule: telemedicine must be provided by a health professional who is licensed, registered or otherwise authorized in the state where the patient is located. The Public Health Code's licensing requirement for each health profession applies to the patient's location, and the state's own telehealth rules for medicine and osteopathic medicine tie prescribing by telehealth to a Michigan license.

The only relief is the exemption list in MCL 333.16171, and none of it fits a virtual clinic. An out-of-state practitioner may act without a Michigan license when a Michigan health professional calls them in for consultation or treatment in an exceptional circumstance. A practitioner who lives adjacent to Michigan's land border with an adjoining state, is authorized there, and whose practice naturally extends across the line may practice in Michigan as long as they keep no office or designated patient-meeting place in the state. The remaining exemptions cover students, military and federal personnel, disaster and epidemic staffing, visiting lecturers, Olympic and athletic team physicians, and spiritual care. CCHP lists no telehealth license or registration process for Michigan.

Michigan is a member of the Interstate Medical Licensure Compact, which CCHP confirms on its licensure compacts section along with Michigan's PSYPACT membership. A physician who qualifies through a state of principal license can obtain a full Michigan license through the compact's expedited process rather than a traditional application. That is the realistic route for an out-of-state physician who needs to join a Michigan roster.

For a brand, the practical rule is that every physician, NP and PA who sees Michigan patients must hold a Michigan license before launch, and because NPs practice under physician supervision here, the supervising physician must also be Michigan-licensed. MyOrbitHealth's network of 2,400+ providers across all 50 states includes Michigan-licensed clinicians, so the brand does not have to build the roster itself.

## Michigan corporate practice of medicine and MSO rules

Michigan has a strong corporate practice of medicine doctrine. Both 50-state guides in our dataset anchor it in section 251(1) of the Michigan Business Corporation Act, which excludes the learned professions from the purposes for which an ordinary business corporation may be formed, and in two Attorney General opinions, Op. No. 6592 (July 10, 1989) and Op. No. 6770 (September 17, 1993), under which the Attorney General treats employing a licensed professional to provide licensed services as the prohibited activity. The PermitHealth guide adds that Michigan had the highest per-capita rate of serious enforcement actions in the country from 2019 to 2021, while non-profits have generally not faced enforcement. The MedPath guide lists non-physician ownership as not permitted and the entity choice as PC or PLLC.

The structure for a non-clinician brand follows from that. Physicians organize under the Michigan Professional Service Corporation Act or form a PLLC under the Michigan Limited Liability Company Act, and only licensed professionals own that entity. The brand or its platform partner operates a management services organization that owns the technology, marketing, non-clinical staff and administrative contracts and charges the professional entity a fair-market-value fee. An ordinary corporation or LLC cannot take part in activities reserved to licensees, which is why employing physicians directly in the brand's operating company is the mistake to avoid.

The dividing line is control of licensed work. Clinical protocols, prescribing decisions, referral patterns, delegation agreements with NPs and PAs, and the hiring and firing of clinicians belong inside the professional entity. Neither guide reports a physician-specific fee-splitting statute, but a percentage-of-revenue management fee still invites the argument that the MSO is practicing medicine. MyOrbitHealth supplies the medical layer through licensed providers under an MSO and friendly professional corporation structure, so a brand entering Michigan owns its customers, records and data while the clinical entity holds the licenses. Confirm the structure with Michigan counsel before launch.

## Michigan nurse practitioner scope of practice

AANP classifies Michigan as a restricted practice state in its May 2026 practice environment map. In AANP's definition, restricted practice means state law requires career-long supervision, delegation or team management by another health provider for NPs to deliver patient care. The AANP Michigan page confirms the category, lists the licensure requirements as an RN license and national certification, and names no pending bill that would change the classification. It does not state any transition-to-practice hours, so we cite none.

For staffing, this means a Michigan NP cannot be the sole clinician on the chart. Prescribing in particular runs through physician delegation, and Michigan's telehealth rules for prescribers require the licensee to be a prescriber acting within scope under MCL 333.16285. The brand's professional entity therefore needs Michigan-licensed physicians available to supervise and delegate to each NP, with the delegation documented and the physician accountable for the delegated acts.

For an asynchronous or video-first clinic, the cleanest model is physician-led visits with NPs working under documented delegation, with the physician's supervision time built into the staffing budget. Confirm current delegation requirements with the Michigan Board of Nursing and the Department of Licensing and Regulatory Affairs.

## How Michigan compares with its neighbors

| State | IMLC | Out-of-state telehealth | NP practice | CPOM |
| --- | --- | --- | --- | --- |
| Michigan | Member | Full license required (MCL 333.16171 exceptions only) | Restricted practice | Strong |
| [Ohio](https://myorbithealth.com/compliance/ohio) | Member | Limited exceptions only | Reduced practice | Limited or unsettled |
| [Indiana](https://myorbithealth.com/compliance/indiana) | Member | Full license required | Reduced practice | Moderate |
| [Wisconsin](https://myorbithealth.com/compliance/wisconsin) | Member | Limited exceptions only | Reduced practice | Moderate |

## 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 Michigan

### Providers already licensed in Michigan

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 Michigan patient is routed to a provider licensed in Michigan, 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 Michigan patients without taking on corporate practice of medicine exposure directly. Your own counsel should still review the arrangement for Michigan.

### Modality and prescribing rules enforced at routing

Orbit Intake and OrbitRx encode state modality and prescribing rules, so an intake that Michigan 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 Michigan, 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 Michigan?

You need Michigan-licensed physicians, a physician-owned professional corporation or PLLC that employs the clinicians, a management services organization for the brand with a fair-market-value fee, Michigan-licensed supervising physicians for any nurse practitioners, and a pharmacy licensed to ship into Michigan. Telehealth prescribing must follow MCL 333.16285, and controlled substances require a bona fide prescriber-patient relationship under MCL 333.7303a.

### Do I need a Michigan medical license to provide telehealth?

Yes. Michigan requires telemedicine to be provided by a professional licensed or otherwise authorized in the state where the patient is located, and there is no telehealth registration. The exemptions in MCL 333.16171 cover exceptional-circumstance consultations requested by a Michigan professional and practitioners living along the state's land border, neither of which supports a direct-to-consumer clinic.

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

Yes. CCHP lists Michigan as a member of the Interstate Medical Licensure Compact, and the IMLCC participating states page is the authoritative source for current status. Physicians who qualify through a state of principal license can obtain a full Michigan license through the compact's expedited process. Michigan is also a PSYPACT member for psychologists.

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

Yes, and it is strongly enforced. Section 251(1) of the Business Corporation Act keeps the learned professions out of ordinary corporations, Attorney General Opinions 6592 (1989) and 6770 (1993) extend the restriction to employing licensed professionals for licensed services, and the PermitHealth guide reports Michigan had the highest per-capita rate of serious enforcement actions in the country from 2019 to 2021. Clinical entities must be physician-owned PCs or PLLCs.

### Can nurse practitioners practice independently in Michigan?

No. AANP classifies Michigan as a restricted practice state, which means state law requires career-long supervision, delegation or team management by another health provider. A brand running NP visits in Michigan needs Michigan-licensed physicians to supervise and delegate prescribing inside the professional entity.

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

Yes, within federal and state limits. The DEA/HHS fourth temporary extension of telemedicine flexibilities runs through December 31, 2026; confirm status on dea.gov. In Michigan, MCL 333.16285 allows telehealth prescribing by a prescriber acting within scope who arranges follow-up and local referral, and MCL 333.7303a requires a bona fide prescriber-patient relationship and follow-up monitoring for Schedule 2 to 5 controlled substances. Confirm current rules with the Michigan Board of Medicine.

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

Brands on MyOrbitHealth go live in days. The provider network of 2,400+ board-certified MD, DO, NP and PA clinicians across 38+ specialties already includes Michigan-licensed providers, the platform supports EPCS with two-factor identity proofing, and prescriptions route to a LegitScript-certified pharmacy network. MyOrbitHealth also prepares and files the brand's LegitScript certification, which is typically approved in days once filed, though LegitScript makes the decision and approval is not guaranteed.

_This is general information, not legal advice._

## Sources

- [CCHP: Michigan cross-state licensing](https://www.cchpca.org/michigan/?category=professional-requirements&topic=cross-state-licensing)
- [CCHP: Michigan online prescribing](https://www.cchpca.org/michigan/?category=professional-requirements&topic=online-prescribing)
- [IMLCC participating states](https://www.imlcc.com/participating-states/)
- [AANP state practice environment](https://www.aanp.org/advocacy/state/state-practice-environment)
- [AANP: Michigan](https://www.aanp.org/advocacy/michigan)
- [MCL 333.16171 (license exemptions)](https://www.legislature.mi.gov/Laws/MCL?objectName=mcl-333-16171)
- [MCL 333.16285 (telehealth prescribing)](https://www.legislature.mi.gov/Laws/MCL?objectName=mcl-333-16285)
- [MCL 333.7303a (bona fide prescriber-patient relationship)](https://www.legislature.mi.gov/Laws/MCL?objectName=mcl-333-7303a)
- [MCL 500.3476 (telemedicine coverage and licensure)](https://www.legislature.mi.gov/Laws/MCL?objectName=mcl-500-3476)
- [Mich. Admin. Code R 338.114 (Board of Medicine telehealth rule)](https://www.law.cornell.edu/regulations/michigan/Mich-Admin-Code-R-338-114)
- [MedPath Compliance: CPOM 50-state guide](https://www.medpathcompliance.com/post/corporate-practice-of-medicine-cpom-50-state-guide)
- [PermitHealth: 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/michigan · facts reviewed 2026-10-18_