Starting a virtual clinic in New Hampshire: 2026 telehealth requirements

Yes. RSA 329:1-d, II provides that an out-of-state physician who provides services by telemedicine to a patient in New Hampshire is deemed to be practicing medicine in New Hampshire and must be licensed under RSA 329. RSA 329:1-b applies the same rule to teleradiology, and RSA 326-B:2 applies it to out-of-state APRNs. RSA 310:7 defines telemedicine and telehealth to include both synchronous and asynchronous interactions, so an asynchronous questionnaire-based visit is still the practice of medicine in the state where the patient sits.

New Hampshire participates in the Interstate Medical Licensure Compact. A physician whose state of principal license is another compact state can use the IMLC's expedited process to obtain a full New Hampshire license. This is the most practical way for a multistate brand to add New Hampshire physician coverage, because the compact produces a full license rather than a limited telehealth credential.

The exceptions in RSA 329:21 do not create a direct-to-consumer pathway. A physician licensed in another state may be called in consultation by a New Hampshire-licensed practitioner who retains responsibility for diagnosis and treatment, and CCHP notes that the board may treat regular or frequent consultation as unlicensed practice. A border physician who lives near a neighboring state, is authorized there, and whose practice extends into New Hampshire is exempt only if the physician does not open an office or appoint a place to meet patients in New Hampshire. A third exception covers a non-resident's regular physician attending them during a temporary stay. None of these fits a telehealth brand enrolling New Hampshire consumers at scale.

The roster implication is that every physician, NP or PA who sees New Hampshire patients must hold the relevant New Hampshire license. Set up intake so New Hampshire patients are routed only to New Hampshire-licensed clinicians, and use the IMLC to expand physician coverage.

New Hampshire is classified as having no general corporate practice of medicine prohibition. The MedPath Compliance guide lists it as a non-CPOM state whose position rests on the professional corporation statute, and the Permit Health guide states that New Hampshire has no formal, codified CPOM doctrine and no specific statutory reference to one. The Permit Health guide points to RSA 294-A, the professional corporation statute, although its source list cites RSA 293-A:1 instead; this page does not resolve that discrepancy.

The practical meaning is that New Hampshire does not, through a statute or attorney general opinion, bar a non-physician-owned company from employing physicians. However, the rules that govern individual licensure still apply in full: RSA 329 licensure requirements, the unprofessional conduct provisions in RSA 329:17, and the physician-patient relationship requirements in RSA 329:1-c. A company that employs clinicians must still leave diagnosis, treatment and prescribing decisions to the licensee, and any compensation arrangement must avoid fee-splitting or payment for referrals.

Most brands that serve New Hampshire alongside other states keep the two-entity structure anyway. A management services organization owned by the brand provides the platform, intake, marketing, billing and administrative functions, while a professional entity owned by a licensed physician engages the clinicians and renders care. Because New Hampshire does not require it, the brand has flexibility in how it organizes the New Hampshire piece, but keeping the structure uniform across stricter states like New York and New Jersey simplifies pharmacy, payer and LegitScript diligence.

The Permit Health guide also observes that many New Hampshire physician organizations are nonprofit and affiliated with hospitals or health systems. That is context rather than a restriction; it does not prevent a for-profit telehealth brand from operating in the state.

AANP classifies New Hampshire as a full practice state, and the compliance dataset this page relies on records the same as of May 2026. Under AANP's definition, New Hampshire APRNs evaluate patients, diagnose, order and interpret tests, and initiate and manage treatment including prescriptions under the exclusive authority of the Board of Nursing, with no required collaborative agreement.

Two New Hampshire statutes shape how NPs deliver telehealth. RSA 326-B:2 deems an out-of-state APRN providing telemedicine to a New Hampshire patient to be practicing in New Hampshire, so NPs must be New Hampshire-licensed. The same section, as CCHP summarizes it, allows APRNs to prescribe after establishing an APRN-patient relationship, with a subsequent in-person examination at least annually for Schedule II through IV drugs; CCHP notes a version of RSA 326-B:11 that requires a subsequent evaluation rather than an in-person exam. For a brand, New Hampshire-licensed NPs can independently staff asynchronous and video visits for non-controlled programs, while controlled-substance programs need a workflow that satisfies the follow-up examination requirement.